Transfer Pricing Agreements

I know there have been several discussions surrounding the issue of transfer pricing, but I am curious if anyone has a transfer pricing or intercompany agreement template that they would be willing to share.  Following are some basics about the situation I am attacking;

US Based company looking to open subs in Latin America and Europe
The company provides online advertising optimization
The subs will initially be structured under the parent at a cost plus arrangement

I know there are numerous tax questions and other variable that need to be addressed but I am attempting to keep it as simple as possible under GAAP/IFRS and IRS requirements.  If that is even remotely possible.

Regards,

Rick