Transfer Pricing Agreement Template – US

Important Notice

The information provided is for general illustrative purposes related to cross-border related-party transaction arrangements. It is not legal or tax advice and should not replace consultation with a qualified professional in international taxation or corporate law. Jurisdictional differences may necessitate modifications to ensure compliance with local laws and regulations. Responsibility for using this example rests solely with the user, and we disclaim any liability for errors, omissions, or consequences resulting from its application without expert review.

Please note: This is a sample Transfer Pricing Agreement template for use within the United States. Actual terms may vary depending on specific circumstances and applicable regulations.

Transfer Pricing Agreement Sample (US)

Parties Involved:

Company A: ABC Corporation
Address: 123 Business Road, New York, NY 10001

Company B: XYZ LLC
Address: 456 Commerce Street, Los Angeles, CA 90015

Transaction Description:

This agreement pertains to the transfer of goods and services between Company A and Company B, under arm’s length conditions consistent with IRS guidelines applicable within the United States.

Transfer Pricing Method:

The parties agree to apply the Comparable Uncontrolled Price (CUP) method to determine arm’s length pricing, subject to compliance with IRS regulations and documentation requirements.

Parties’ Responsibilities:

Each party shall maintain appropriate documentation to substantiate transfer prices and shall cooperate fully during any audits or inquiries from tax authorities.

Governing Law:

This agreement shall be governed by the laws of the United States and applicable state regulations. Disputes shall be resolved in courts within the jurisdiction where the primary transaction occurs.

Additional Provisions:

• Both parties shall maintain transfer pricing documentation in accordance with IRS requirements.
• Any amendments to this agreement shall be made in writing and signed by authorized representatives.
• In case of dispute, arbitration may be pursued prior to litigation.

New York, ______________________