Global Transfer Pricing Documentation

Transfer pricing documentation is increasingly a required compliance effort for most MNEs. The old days of “opting in” for transfer pricing documentation for penalty protection are gone in many jurisdictions.  With the adoption of OECD’s BEPS Local File, Masterfile, and CbCR recommendations, tax administrations increasingly require the preparation of transfer pricing documentation rather than allowing taxpayers to opt-in.

TP Analytics is well experienced at designing and delivering transfer pricing documentation that is cogent, practical, defensible, timely, and compliant with the ever-evolving international and local transfer pricing guidance.

When planning global transfer pricing documentation, MNEs can consider different approaches depending on the group’s facts and strategy.

At TP Analytics, we believe that defining a comprehensive strategy for documentation is imperative, considering that transfer pricing documentation is the one opportunity that MNEs have to tell the story that underlies their tax and transfer pricing operating model.  The one template fits all is no longer applicable, and a well-defined strategy based on the group’s facts helps to ensure a documentation process that is efficient, compliant, globally consistent, and accurate.