Transfer Pricing

Required Inputs

• Group Structure: Entities involved, jurisdictions, and ownership chain.
• Intercompany Transactions: Types (goods, services, IP, financing), volumes, and current pricing.
• Functional Profile: Functions performed, assets employed, and risks assumed by each entity (FAR profile).
• Industry Context: Sector, competitive dynamics, and market conditions affecting pricing.
• Jurisdictions: Countries involved and their specific TP rules and documentation thresholds.
• Financial Data: Segmented P&L by entity, intercompany balances, and consolidated financials.
• Existing TP Documentation: Current policies, benchmarking studies, intercompany agreements.
• Dispute History: Any ongoing or past TP audits, adjustments, or competent authority proceedings.

Execution Steps

1. Intercompany Transaction Identification and Categorization

Map all intercompany transactions across the group: