You built your business with a sophisticated, multi-entity structure for a reason. Whether it’s a US LLC paired with a UK Ltd or a similar cross-border setup, you created it to gain a liability shield, unlock new markets, and operate with tax efficiency. But this powerful architecture rests on a single, critical discipline: treating your companies as genuinely separate entities.
This is where transfer pricing comes in.
Forget the intimidating corporate jargon. At its core, transfer pricing is simply the price one of your companies charges your other company for goods, services, or intellectual property. If your US entity develops a strategy that your UK entity uses to win a client, the UK company must "pay" the US one for that work. This internal transaction, while between related parties, must be handled with the same commercial logic as a deal between strangers.
The entire system rests on one golden rule: the arm's length principle. It mandates that the price you set between your own companies must be the same as if they were two independent businesses negotiating in the open market. The simplest test is to ask: What would I pay a third-party firm for this same service? That is your arm's length price. This principle ensures profits are taxed where value is created, preventing the artificial shifting of income to lower-tax jurisdictions.
Mastering this isn't just about compliance; it's about protecting the very advantages you worked so hard to build.
For a solopreneur, the consequences of mismanaging transfer pricing are disproportionately severe. The risks aren't abstract; they are concrete threats that can destabilize your business.
These risks are serious, but they are entirely manageable. By adopting a disciplined, proactive approach, you can transform transfer pricing from a source of anxiety into a fortress for your business. This simple, three-step playbook is designed to give you control, demonstrate professionalism, and build a defensible record.
Your first and most powerful tool is a formal contract between your two companies: the Intercompany Agreement (IA). Think of this not as a bureaucratic chore, but as the constitution for your global business. It proves to tax authorities that your internal dealings are deliberate, professional, and governed by a clear commercial framework.
This document formalizes the terms of engagement before any work is done. It should be the single source of truth for how your entities collaborate.
Your "Contract with Yourself" Checklist
An agreement is a statement of intent; the invoice and payment are the tangible proof. This step is about bringing your IA to life through consistent, professional execution, creating a clean paper trail that any tax authority can follow.
Here’s how to translate your agreement into action across common scenarios:
Scenario 1: The Consultant
Your US LLC develops a marketing strategy, but the client contract is with your UK Ltd. The UK Ltd is essentially "hiring" the US LLC for the strategic work.
Scenario 2: The Developer
Your US entity owns the intellectual property (IP) for a piece of software. Your European entity licenses it to serve local clients.
Scenario 3: Shared Costs
You pay for a $1,000 software subscription through your US LLC, but you use it 60% for US projects and 40% for UK projects.
Many entrepreneurs fear they need a $20,000 formal transfer pricing study. For a solo-operated business, this is usually unnecessary. Your goal is to create contemporaneous documentation—a simple, organized file you build in real-time to prove you’ve made a reasonable, good-faith effort to comply. This file is your first and best line of defense.
Your Compliance File Checklist:
Your memo can be as simple as this:
Spending a few hours to assemble and maintain this file is the highest-ROI administrative task you can perform.
Transfer pricing does not have to be a source of fear. By implementing this straightforward framework, you transform a compliance task into a strategic asset. You are not just satisfying tax authorities; you are validating the integrity of your global structure, sharpening your operational discipline, and building a more resilient enterprise.
You made the intelligent choice to build a business for global reach. Honoring that structure with professional diligence is the final step. This playbook provides the clarity and control to manage your international operations with the same expertise you bring to your clients.
An international business lawyer by trade, Elena breaks down the complexities of freelance contracts, corporate structures, and international liability. Her goal is to empower freelancers with the legal knowledge to operate confidently.
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