Topic collection
Documentation & compliance
The three-tiered documentation standard introduced by BEPS Action 13 is now the compliance backbone in most jurisdictions. Penalty protection usually depends on getting the timing right, not just the content.
Controlled transaction
4 minA transaction between two associated enterprises, and therefore the unit that transfer pricing rules test.
Master file
4 minA group-level document giving tax authorities a high-level overview of the multinational's business, intangibles, financing and transfer pricing policies.
Local file
4 minCountry-specific documentation covering the local entity's material controlled transactions and the analysis supporting their pricing.
Country-by-country reporting (CbCR)
5 minAn annual report by large multinational groups showing revenue, profit, tax, employees and assets for every tax jurisdiction in which they operate.
Year-end adjustment
5 minAn adjustment made by the taxpayer before or at year end to bring a controlled outcome into the arm's length range.
Transfer pricing risk assessment
4 minA structured review identifying which controlled transactions are most likely to attract challenge and what the exposure would be.
Book a TP Health Check
Unsure how your transfer pricing would hold up?
A fixed-scope review of your intercompany pricing, documentation and audit exposure — scoped to your jurisdictions, delivered as a written risk memo. First response within one business day.