Transfer Pricing Documentation

Evolving TP documentation from compliance to value creation

Transfer pricing documentation is the process by which global companies create and save documentation describing the nature of intra-group transactions and the reasonableness of prices.

In recent years, global companies have been faced more than ever with the need to effectively manage transfer pricing documentation. The OECD's transfer pricing taxation recommendations have added additional requirements to national laws and regulations, and national tax authorities expect detailed transfer pricing documentation that can be scrutinized during tax audits.

Deloitte Tohmatsu can assist with transfer pricing documentation from both strategic and tactical perspectives. We not only document transfer pricing as a compliance response but also introduce approaches, tools, and technologies that improve the client's transfer pricing documentation process and operating model, increase efficiency, and generate valuable insights by aligning the client's internal resources with Deloitte Tohmatsu's resources.

Being able to maintain consistency in transfer pricing documentation in individual countries without incurring significant resources and costs has become a critical issue for global companies.

Many global companies are outsourcing some of their transfer pricing activities and seeking advisors who can assist them in a variety of ways, including benchmark analysis, functional analysis, local file preparation, master file preparation, and reconciliation between transfer pricing documents. Deloitte Tohmatsu understands the challenges ahead and can offer flexible approaches to solving these issues.

Learn more about Operational Transfer Pricing and how Deloitte can help you

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