Business owners who move money, goods, or services between commonly controlled entities are subject to IRS transfer pricing rules, which require that intercompany transactions be priced as if they were conducted between unrelated parties. When those prices are not set correctly, the IRS has authority under IRC Section 482 to reallocate income and assess back taxes, interest, and penalties that can reach 20% to 40% of the resulting underpayment. With the right documentation and a deliberate approach to pricing, most small and mid-size business owners can manage this exposure without complex or costly studies.