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Transfer Pricing Documentation

Deloitte’s transfer pricing team helps companies manage risks by aligning transfer pricing solutions and the operation of their transfer pricing policies with their global business operations and objectives, assisting them in meeting compliance requirements including preparation of documentation to support their policies and practices, and resolving disputes efficiently.




Transfer Pricing Planning




Dispute prevention and resolution

Transfer pricing documentation

International businesses are faced with increasingly onerous transfer pricing documentation requirements in different countries. For most businesses, complying with all these requirements is a challenge. Deloitte supports businesses both in determining a strategy for meeting transfer pricing compliance requirements and through the steps required to prepare transfer pricing documentation. Deloitte’s risk assessment approach, which assists with determining how to prioritize transfer pricing documentation requirements as well as taking account of the business drivers and the more practical aspects of  preparing documentation, such as the availability of resource, enables the preparation of a detailed individual workplan that takes into account the need to manage risk along with the needs of the business.

When it comes to preparing documentation, Deloitte recognizes that there is not a ‘one size fits all’ approach for businesses. Deloitte’s flexible approach breaks the transfer pricing documentation process into its component parts and focuses on where the most value can be added. This ranges from a full outsource of the process through to input on the more complex transfer pricing areas. Deloitte’s team of transfer pricing specialists offers significant experience in all stages of the transfer pricing documentation process, in particular, the selection and application of transfer pricing methods, articulating how complex businesses, operate in order to support the transfer pricing approach and practical experience of local transfer pricing requirements and tax authority approaches.

Alongside this flexible approach, Deloitte have developed a technology enabled, web-based solution, TP Digital DoX, which enables us to collaborate with our clients to adopt a centralized transfer pricing documentation approach and deliver consistent, efficient and streamlined documentation across multiple territories.