Treat structure as infrastructure - not paperwork - and value follows.
The Entity Atlas point of view
Leaders in cross-border structure
Structure for profitable global growth.
Entity Atlas builds cross-border frameworks that align entities, transfer pricing, customs, payments, and records - supporting companies expand with clarity, compliance, and confidence.
Built around public guidance, real operating evidence, and qualified adviser review points - not shortcuts or one-size-fits-all templates.
Intercompany Agreement · v2.4
ExecutedIntercompany Master Services Agreement
Between Principal Co. (UK) and OpCo US, Inc.
1. Pricing methodology
2. Scope of services
3. Term & termination
Authorised signatory
DocuSigned by:
4F2A9C8B6E1D4A7
Docusign Envelope ID: 9F3A1C7E-4B82-4D6A-A1E5-7C9B2D8F4E60
Eleanor Whitfield
Director · Signed 14 May 2026
AES-256 encrypted
Envelope completed· 2 of 2 parties signed
Leading commerce experts
Entity Atlas handles global commerceend to end, at scale.
We keep your structure compliant and operational across the platforms you sell on, the rails you move money through, and the authorities you answer to - one team across the entire stack.
Some of our operational partners
Why Entity Atlas
Run global entitieswithout the chaos.
From entity design to tax, customs, and monthly books - Entity Atlas runs the operational backbone of your cross-border business across four core services, so your structure scales as fast as your sales and expansion never outpaces the framework behind it.
One team for your entire global stack.
Structuring, tax, customs, and books - run end to end by specialists who do this every day, so your advisers review one clean framework instead of rebuilding it from scattered records.
Entity structuring
Design the group - who sells, owns IP, holds stock, and collects cash - with transfer pricing and intercompany agreements built in.
Global tax and remittance
VAT, IOSS, and corporate tax across jurisdictions, plus compliant payment flows and profit remittance between your entities.
Bookkeeping and records
Intercompany ledgers, monthly close, and audit-ready evidence - every agreement, calculation, and source file kept in order.
Commerce and customs
HS classification, landed cost and duty, a customs and broker team, plus IOR and merchant-of-record - with margin and market optimization built in.
Instant estimate
Price your cross-border setupin a few clicks.
Pick the services you need and choose the countries to see indicative mid-market pricing. It is a guide, not a final quote - select your services and one of our consultants will confirm the scope and prepare your formal quote.
What do you need?
Add a service to start your estimate
Registrations, tax filings, bookkeeping, transfer pricing, customs and more.
Your estimate
Indicative mid-market pricing
Your selected services and estimated pricing will appear here.
Integrations across thousands of leading platforms
Global commerce experts
Compliant transfer pricing, built to support your business.
Set your intercompany pricing right and the benefits cascade - a lower customs value, cleaner VAT, and records an auditor can actually follow.
What you get
Defensible pricing matched to what you sell and ship
Intercompany agreements drafted and signed, not left as a gap
The documentation an auditor actually asks for
Big-4 & law firms
$40–80k+
Typical cost for the benchmarking study, intercompany agreements, and transfer-pricing documentation.
Entity Atlas
from$9K
Drafted documents, fixed and one-time - the same framework an auditor actually asks for.
How your structure connects
Swipe to explore the full map
Entity Atlas
Transfer Pricing
Core documents
Transfer Pricing Memo
Intercompany Agreement
Customs Valuation Support
Intercompany Ledger Setup
Final customer destinations
AU
EU
USUK
SG
HKStructuring tax and duty across 200 countries & jurisdictions.
Transfer made easy
Set up your structure in five simple steps
Built for growing businesses doing under $20M in revenue. From your first form to a fully drafted framework - here is exactly how it works.
Start your structure
Step 1 of 4Principal entity
Prada Italy
Distribution channel
Prada USA
Annual revenue
Under $20M
A few quick questions
Sells online / via ShopifyYes
IP held in the principalYes
Staff employed in-marketNo
- 1
Step 1
Tell us your structure
Add your principal (e.g. Prada Italy) and the distribution channel it sells into (e.g. Prada USA), then answer a short questionnaire about how your business operates.
- 2
Step 2
Get your structure + quote
We design the structure and framework that fits your model and send back a clear, fixed quote - no surprises.
- 3
Step 3
Verify, then we draft
Accept the quote and payment is processed. We verify you're the authorised representative for the principal and distribution entity (about 48 hours), then our experts draft your framework - typically within 7-10 business days.
- 4
Step 4
Choose how you run it
Keep everything in your own portal, hand the ongoing filings to us, or have us run the whole group at scale. Three options, below.
Step 5
Entity Atlas drafts your framework
Tender and entity documents, drafted by our experts - from $9,000 USD per entity, depending on complexity (one-time setup).
Then choose how you run it - ongoing
Your drafted framework, kept compliant in one place.
$500-999USD / month
Recommended
We run it end to end so your team keeps shipping.
From $4,500USD / month
- Everything in the portal, included
- Up to 2 entities across supported markets
- Entity Atlas acts as your appointed authorised agent
- Company tax, sales tax & IRS filings (US)
- Compliance HS code audits & ongoing maintenance
- Bookkeeping, filings & remittance handled
Get in touch
Jurisdictions outside these are quoted independently.
For groups with multiple entities, local staff, or a physical presence in-market.
From $15,000USD / month
What we handle
Everything you need to scale across borders
One managed partner for global tax, transfer pricing, structuring and profitability - from entity setup to year-end compliance.
Transfer Pricing
Defensible intercompany pricing and framework
Global Structuring
Entity structures built for international growth
Profitability Analysis
True margin across every market
Fully managed
Your entire global tax function, handled
One partner across 200+ markets - structuring, filings and advisory, end to end.
International Tax Lawyers
Specialist cross-border legal counsel
Auditors
Independent audit and assurance
Accountants & Bookkeeping
Clean books, filing-ready year-round
Structure & margin estimator
Find the right structure for your business
Answer a few quick questions. By the end, you will know exactly what setting up - and running - your structure involves, and three things in particular:
Online or bespoke?
Whether you can handle all of this online through Entity Atlas, or need deeper bespoke legal drafting.
How much profit stays in the US?
The routine margin your US entity should keep, anchored to the OECD Amount B range.
Do you need benchmarking?
Whether your footprint is simple enough to skip a formal benchmarking exercise - or complex enough to need one.
What structure does your business need?
Step 1 of 6 · Footprint
Where your parent or operating company (the principal) sits today. You can change this any time.
The market you are selling into and structuring for.
Used to anchor benchmarking to the right industry (SIC classification).
Benchmarking
What is benchmarking?
Think of benchmarking as the receipts behind your numbers. It is how we work out what your entity should fairly earn - and back it with recognised data and methodology, not guesswork. So if a tax authority ever asks “why this margin?”, you already have a clear, documented answer ready.
Distribution model
Risk assessment
For a general distributor, the routine return on sales signals transfer-pricing risk. The lower it runs, the more scrutiny it tends to attract.
1086420
Target ~3.0-3.5%
Return on sales %
High riskBelow 2.1%
Medium risk2.1% - 5.3%
Low riskAt or above 5.3%
Indicative bands for a general distributor, aligned to the OECD Amount B routine range. A planning target around 3.0% to 3.5% keeps a routine US or UK distributor inside the defensible zone - documented, not guessed.
Our planning methodology
Built around recognised transfer pricing concepts.
- Identify the tested party1
- Map functions, assets, and risks2
- Separate goods pricing from service, IP, and residual payments3
- Test the distributor's result using operating margin on net sales4
- Benchmark or validate the margin where required5
- Document when adviser sign-off is needed6
OECD Amount B anchor
1.5–5.5%
Routine return on sales (matrix range)
3.0–3.5%
Practical early-stage planning target
OECD Amount B introduces a simplified return-on-sales matrix for certain in-scope baseline marketing and distribution activities. Public summaries describe routine distributor outcomes generally ranging from about 1.5% to 5.5% return on sales, depending on industry and operating intensity. For many early-stage ecommerce distributor structures, a planning target around 3.0% to 3.5% can be a practical starting point.
View OECD Amount BWhat this looks like in practice
US distribution entity
A routine distributor selling into the US, carrying limited local functions and risk, lands at a 3.0–3.5% return on sales - benchmarked against comparable independent distributors. A defensible margin we can document, not a guess.
UK distribution entity
Selling into the UK works the same way. A UK reseller importing and distributing locally, with the same limited-risk profile, sits in a comparable routine band - benchmarked against independent UK and European distributors using OECD guidance and HMRC’s transfer pricing approach.
But the number is never automatic
The right margin depends on the facts:
- Who owns the brand
- Who controls pricing
- Who manages suppliers
- Who bears inventory risk
- Who pays for marketing
- Who owns customer relationships
- Who imports the goods
- What records are maintained
Reference points we design around
Built around recognised compliance frameworks
Entity Atlas builds the framework and evidence pack. Where required, the final margin is validated by a qualified transfer pricing adviser.
Related-party transaction value
CBP's informed-compliance guidance on proving an arm's-length customs value between related parties - evidence, not assumptions.
U.S. Customs & Border ProtectionVisit official source
19 CFR §152.103 - Transaction value
The federal regulation defining transaction value and how related-party prices are tested for acceptability.
U.S. Code of Federal RegulationsVisit official source
Customs valuation & transfer pricing
The WCO guide on how customs valuation and transfer pricing interact - written for administrations and the private sector alike.
World Customs OrganizationVisit official source
Transfer pricing record-keeping
The ATO's simplified record-keeping options and documentation expectations under Australia's transfer pricing rules.
Australian Taxation OfficeVisit official source
Form 5472 instructions
IRS instructions confirming Form 5472 applies to 25% foreign-owned US corporations - including disregarded entities - with reportable transactions.
U.S. Internal Revenue ServiceVisit official source
Transfer Pricing Guidelines
The OECD's guidance on applying the arm's-length principle for multinational enterprises - the global baseline tax administrations build on.
OECDVisit official source
Pillar One - Amount B
The OECD's streamlined approach for pricing baseline marketing and distribution - the public anchor we use for routine distributor returns.
OECDVisit official source
PCG 2019/1 - distributor profit markers
The ATO's practical compliance guidance on the profit markers it expects from inbound distributors.
Australian Taxation OfficeVisit official source
INTM440000 - UK transfer pricing
HMRC's international manual on how UK transfer pricing rules apply to intercompany pricing and distribution.
HM Revenue & CustomsVisit official source
Public references like OECD Amount B act as a planning anchor for routine distributor returns - a sanity-check on whether a proposed margin is directionally reasonable. They don't replace client-specific benchmarking or adviser review.
As you grow or pass higher revenue thresholds, we recommend a final benchmarking study specific to your business - which Entity Atlas can support.
Two paths, one parcel
The structure decides the duty base
How a business is structured carries real financial weight - the right distribution model can change the value duty is assessed on. The example below shows how it works, grounded in OECD guidance and 19 CFR §152.103.
Worked example·Illustrative
Women's leather jacketPrada
MFN 6%+Sec. 301 7.5%+IEEPA 15%=≈ 29%
Traditional direct to consumer
Scenario A
- Online storeOrder $2,200No intermediary
- US CustomsValues $2,200
- CustomerUnited States
Online store
Order $2,200
No intermediary
US Customs
Values $2,200
Customer
United States
Duty per order
$0
29% on $2,200 retail
Entity Atlas distribution model
Scenario B
- Online storeOrder $2,200
- Prada ItalyTransfer price $700
- Prada US LLCImporter of record
- US CustomsValues $700
- CustomerUnited States
Online store
Order $2,200
Prada Italy
Transfer price $700
Prada US LLC
Importer of record
US Customs
Values $700
Customer
United States
Duty assessed on transfer price
Compliant transfer pricing, built to support your business
Set up & maintained by Entity Atlas
Intercompany distribution agreementTransfer pricing memoCustoms valuation fileIntercompany ledgerDuty reduced from $638 to $203, saving $435 per order (68% less duty).
$0
68% less duty
The same approach applies to every order. The right structure varies by market, so we tailor and handle it for each one.
Fully handled for you. Most firms stop at transfer pricing - we don't. Our full managed service maintains all four documents, plus IRS filings, State & Nexus tax, and the substantiation framework. Your team keeps shipping and selling, not chasing paperwork.
One command center for your whole structure
A working preview of the Entity Atlas workspace. Click any item in the sidebar to explore - every entity, document, filing and integration in one place.
app.entityatlas.io
SMLumar FashionGroup
Search
Workspace
Group Overview
Lumar Fashion - structure, documents and filings at a glance
Active entities
3
Documents signed
12/14
2 awaitingNext filing
21d
Form 5472TP health
Compliant
Reviewed MayEntities
Document signing
Intercompany MSA
2 of 2 signedIP Licence Agreement
2 of 2 signedTransfer Pricing Memo
FinalisedManagement Services Agt.
Awaiting Lumar EuropeLanded cost efficiency+18% YTD
Efficiency index
118
vs January
+18%
Duty leakage saved
£71K
JanFebMarAprMayJun
Entity Atlas audit pack6 files
Master File.pdfLocal File (US).pdfLocal File (EU).pdfIntercompany Agreements.pdf+2 files
Flagged for review? We move fast.
When a tax authority opens an enquiry, we prioritise your case. We work directly with your advisers and get a complete, consistent documentation set in place - often under tight deadlines. You leave with the Master File, Local Files, and signed intercompany agreements an auditor expects to see.
Every file version-controlled and signed via Docusign
Full coverage
The future of business structure
Most firms hand off transfer pricing and stop. We carry it through to the journals and the files an auditor actually asks for.
Understand your business
Structure & TP model design
Intercompany agreements
Accounting implementation
Year-end journals
Local & Master Files
Entity Atlas
Traditional firms
Coverage
Atlas
Traditional
Understand your business
Structure & TP model design
Intercompany agreements
Accounting implementation
Year-end journals
Local & Master Files
Future strategyStructure first.
Structure first.
Scale without limits.
The businesses that win design their group structure and transfer-pricing framework early - turning a scramble at tax time into a foundation for growth.
In practice
Every entity mapped, every intercompany flow documented and signed.
Entity Atlas global offices
Operating across the world's major financial and trade hubs.
Powered by
Bank-grade e-signature, built in.
Structure documents are sensitive. Every agreement is signed, sealed, and stored through Docusign's enterprise infrastructure - so what you execute today still holds up under scrutiny years from now.
AES-256 encryption
Every document encrypted in transit and at rest, end to end.
SOC 2 Type II
Docusign's signing platform is independently audited to SOC 2 Type II.
eIDAS & ESIGN
Enforceable e-signatures under eIDAS and the U.S. ESIGN Act.
Tamper-evident trail
Every view, signature, and timestamp permanently recorded.
Certificate of completion
A sealed certificate issued for every executed envelope.
Institutional-grade transfer pricing frameworks, built to stand up to investor diligence and tax authority scrutiny - so your finance team moves with total confidence.
Structures designed to the same standard the world’s largest firms hold themselves to.
Get started
Structure your operations properly, from the start.
Arrange a consultation to map your group structure and transfer pricing framework with our specialists.
Get in touch
30 minutes · no obligation