Transfer Pricing Articles & Guides

Transfer pricing guides for startups with foreign subsidiaries: the arm's-length standard, cost-plus agreements, documentation, penalties, and cross-border tax forms.

1 article — Updated October 2026

Transfer Pricing

Oct 11, 2026

-13 min read

Transfer Pricing for a Foreign Subsidiary: Cost-Plus R&D Agreements Explained

How a U.S. startup should price its foreign R&D subsidiary: cost-plus intercompany agreements, a worked example, benchmarking the markup, Section 6662(e) penalties, and the documentation to keep.

The Complete Guide to Transfer Pricing for Startups

What tax authorities expect of intercompany pricing, which methods apply, what to document, and where founders go wrong when they have a foreign subsidiary.

Read the Complete Guide