Transfer Pricing Documentation

Transfer pricing documentation records related-party transactions, the business context and the analysis supporting the chosen pricing approach.

Taxpayers, finance teams and group tax managers reviewing a transaction, a reporting requirement or an authority communication can use this service to clarify a particular issue. A useful starting question is: “Can a global report replace local transaction evidence?” Begin with the facts behind that question rather than assuming that a standard package will resolve it.

The engagement can cover the following workstreams. The proposal specifies which apply to your matter and what evidence or specialist input is needed.

• Prepare transaction and functional descriptions.
• Document method selection and comparability.
• Align supporting schedules with accounts.

Start with the records below where available. They help establish the facts before a more specific checklist is agreed.

• Agreements.
• Transaction schedules.
• Segmented results.
• Benchmark evidence.

Provide the relevant entity, transaction or reporting period and any existing notice or deadline. Identify missing or inconsistent records so they can be addressed explicitly.

A generic group report may not explain the local entity’s actual transactions, functions or financial results.

1. Define the question: prepare transaction and functional descriptions, using the available agreements and the facts you provide.
2. Examine the evidence: document method selection and comparability. Record unresolved information and the assumptions that affect the analysis.
3. Agree the action: align supporting schedules with accounts. Set the required deliverables, responsible owners and any follow-up or external dependency.

The proposal for Transfer Pricing Documentation sets out the analysis, documentation or coordination deliverables and the work you retain. The availability of agreements, transaction schedules, segmented results and benchmark evidence affects readiness and the amount of follow-up needed. Fees and the working schedule are agreed after that initial assessment. Any required independent report, legal representation or authority application is identified as a separate responsibility where relevant.

Use these official resources for the relevant framework. Application to a particular entity, period or jurisdiction requires a separate assessment.

• Income Tax Department: Applicable tax periods and framework

• Transfer Pricing & International Tax Advisory
• Transfer Pricing Policy Development
• Transfer Pricing Audit & Risk Review
• Transfer Pricing Dispute Resolution

Share a short summary of your Transfer Pricing Documentation requirement and the records already available. BIATConsultant can assess the proposed scope and explain the next steps.

• Request a Transfer Pricing Documentation consultation
• About BIATConsultant