TP Documentation

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TP Design & Implementation TP Compliance TP Documentation International Tax Consulting TP & International Tax Training TP & Tax Diagnostics Automation
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Build robust and defensible transfer pricing documentation tailored to regulatory expectations.

Our analysis ensures your pricing, policies, and agreements withstand audit scrutiny.

TP Policy

A TP policy establishes the group-wide framework for pricing, responsibilities, documentation, and compliance. Companies need a TP policy when scaling operations, restructuring, completing an M&A transaction, onboarding new entities, or creating a consistent approach across jurisdictions. It ensures clarity for finance, tax, legal, and operational teams.

What we do:
  • Draft clear and consistent TP policies aligned with your business model and regulatory requirements.
  • Define roles, responsibilities, pricing logic, and documentation expectations.
  • Align the TP policy with the Master File, Local Files, benchmarking, and intercompany agreements to ensure full consistency.
Our Experience:
  • Drafting TP policies for SaaS, software, fintech, health-tech, manufacturing, logistics, e-commerce, and shared-service groups.
  • Integrating TP policies following mergers and acquisitions, including post-M&A alignment for a listed Swiss multinational.

Benchmarking

Benchmarking analyses substantiate the arm’s length nature of intercompany pricing using independent market data. Companies need benchmarking for TP documentation, audits, pricing updates, and compliance with OECD/local TP laws.

What we do:
  • Perform global benchmarking using CUP, TNMM, RPM, CPM, and financial analyses.
  • Apply structured quantitative and qualitative screening to identify reliable comparables.
  • Prepare transparent, audit-ready benchmarking reports.
Our Experience:
  • Benchmarking services, royalties, distribution, procurement, management fees, loans, guarantees, R&D, and back-office transactions.
  • Using RoyaltyRange, Orbis, Amadeus, LoanConnector, Capitaline, and Bloomberg across multiple industries.

Intercompany Agreements (IC Agreements)

Intercompany agreements legally define the terms, pricing, and responsibilities between related entities. They are needed during new transactions or audits to ensure legal enforceability and alignment with TP positions.

What we do
  • Draft and review IC agreements covering services, goods, intellectual property, financing, distribution, and shared services.
  • Ensure consistency with TP policies, actual conduct, and regulatory expectations.
  • Coordinate with legal, finance, and tax teams for seamless implementation.
Our Experience:
  • ICAs for intangible licensing, service fee models, procurement hubs, distribution arrangements, management fees, and financing flows.
  • Experience across software, fintech, D2C/e-commerce, health-tech, global capability centres, and multinational groups.

FAQs – Quick Reads

Yes. An effective transfer pricing policy relies on clear, consistent, and robust accounting policies to ensure transparency, accuracy, and ease of audit compliance.

Typically, every 2–3 years per transaction, unless material changes occur.