Documentation That Supports Your Pricing Decisions

The Challenge You're Facing

Operating entities in multiple countries means transactions between your own companies. Tax authorities in each jurisdiction naturally want assurance that these intercompany prices reflect what independent parties would agree to. Without proper documentation, demonstrating this becomes difficult.

Many organizations set their intercompany prices based on reasonable business logic but haven't formalized the rationale in writing. When questions arise, explaining the thinking behind pricing decisions from memory creates uncertainty. The documentation gap leaves you vulnerable during reviews, even when the underlying pricing is appropriate.

Creating transfer pricing documentation internally requires specific expertise and considerable time. It involves economic analysis, comparability studies, and detailed transaction documentation. Your team may recognize the need but struggle to find the bandwidth to address it while managing daily operations.

Working Together on Your Documentation

The process begins with information gathering. We review your organizational charts, intercompany agreements, and financial data showing the volume and nature of cross-border transactions. Initial conversations help us understand the business reasons behind your current structure and pricing.

As we develop the documentation, we share drafts for your review. This collaborative approach ensures the final reports accurately reflect your operations and that we've captured important context about how your business works. Your input helps us refine the analysis and address any areas needing clarification.

We present the completed documentation in a review session where we walk through the key findings and explain the analysis. This gives you the opportunity to ask questions and ensures you're comfortable with the positions taken. You'll understand not just what the documentation says but why particular approaches were selected.

After delivery, we remain available to discuss the documentation with your tax advisors or to address questions that arise during regulatory reviews. The documentation is yours to use as needed, and we're here if you need support explaining or defending the positions.

How Progress Becomes Visible

The typical documentation project takes 6-8 weeks from information gathering to final delivery. You'll see draft sections as we complete them, giving you visibility into progress and the opportunity to provide feedback throughout rather than waiting for a finished product.

The completed documentation provides clear evidence of due diligence. When regulators ask about your transfer pricing, you'll have prepared reports ready to share rather than scrambling to compile information retrospectively. This shift from reactive to prepared affects how those conversations unfold.

Organizations that maintain current transfer pricing documentation typically experience smoother regulatory interactions. Questions still arise, but they're addressed within the framework of existing documentation rather than requiring new analysis under time pressure.

The documentation also becomes a reference tool for your finance team. When considering new intercompany arrangements or changes to existing ones, you'll have a baseline understanding of your current approach and the principles that should guide future decisions.

Moving Forward

Starting involves a conversation about your organizational structure and intercompany arrangements. We discuss which transactions are significant, what documentation currently exists, and whether any regulatory reviews are pending or anticipated.

Based on that discussion, we provide a specific proposal outlining the scope of documentation we'd prepare, the information needed from you, and the timeline for completion. This gives you clarity on exactly what the project entails before making a decision.

Once you decide to proceed, we send a detailed information request and schedule initial working sessions with your team. The information gathering phase is intensive but focused. We work efficiently to minimize the time required from your staff while obtaining what's necessary for thorough documentation.

As we complete sections of the documentation, we share them for your review. This ongoing feedback loop ensures the final product accurately reflects your operations and addresses the questions most relevant to your situation.