Transfer pricing

Transfer pricing in international trade and supply chains.

Transfer pricing frameworks for international trade transactions, intercompany arrangements, and cross-border supply chain structures.

Transfer pricing applies wherever related entities transact across borders — and the intersection with customs valuation, trade finance, and supply chain structures creates compounding complexity. Pricing that satisfies one jurisdiction's requirements may create exposure in another.

Organizations with intercompany trade flows need consistent, defensible transfer pricing that accounts for trade terms, logistics, risk allocation, and jurisdictional requirements. Documentation must hold up under audit across multiple authorities simultaneously.

Common risk areas

Where organizations typically encounter exposure in this area.

  • Transfer prices inconsistent with arm's-length standards triggering adjustments
  • Customs valuation and transfer pricing positions that conflict under audit
  • Inadequate contemporaneous documentation for intercompany trade transactions
  • Profit allocation that does not align with functional analysis and risk assumption

How Dominion helps

Practical support for organizations managing this exposure.

  • Transfer pricing policy design for intercompany trade and service arrangements
  • Customs-transfer pricing alignment analysis to reduce dual-adjustment risk
  • Documentation preparation and benchmarking for cross-border transactions
  • Support for advance pricing arrangements and competent authority proceedings

Insights

Navigating tariff classification for cross-border goods

How classification decisions affect duty rates, compliance exposure, and supply chain costs across jurisdictions.

Read

Export controls and the technology supply chain

Practical context for technology and dual-use goods crossing international borders under multilateral control regimes.

Read

Trade finance and AML compliance

How AML obligations apply across trade finance instruments and cross-border payment structures.

Read

Looking for strategic trade advisory support?

Dominion Partners provides integrated trade, treasury, and regulatory advisory for organizations operating internationally.

Speak with us