Plan: Transfer pricing — from $2,400 in year one
Transfer pricing for groups with a US entity
Reviewed by Thiago Vieira — Lawyer admitted in Brazil (OAB) and Portugal (OA), founder of Pactum Global · Reviewed on October 12, 2026
When your US LLC or Corp pays or charges a related company in Brazil, Portugal, Mexico or Colombia, the price must follow the arm's length principle — what independent companies would charge each other. Without documentation, tax authorities can adjust the price, assess extra tax and impose penalties.
What's included
- Full economic study with a US-prepared comparables benchmark
- Guidance memo signed by Thiago Vieira, lawyer (OAB/OA)
- Intercompany agreements reflecting the study's policy
- Annual benchmark update
- Base: 2 entities and 2 jurisdictions — $2,400 year one, $1,200/year renewal
- Extra entity: $1,200 year one · $600/year. Extra jurisdiction: $600 · $300/year
- Everything in the Starter contracts plan included
Who needs it
Groups with a US entity and a related company abroad exchanging services, royalties, loans or goods.
Frequently asked questions
How much does a transfer pricing study cost?
At Pactum, $2,400 in year one for 2 entities and 2 jurisdictions, renewing at $1,200/year.
Who prepares the benchmark?
A US-based team member and former tax auditor at the Israel Tax Authority, with legal review by Thiago Vieira.
What is an intercompany agreement?
A contract between group companies formalising the service, price and terms set in the study.