Transfer Pricing Document Checklist
Friday, September 25th, 2009Larry Harding, founder and president of High Street Partners, says transfer pricing documentation varies by country, but typically includes:
• An overview of the business
• An analysis of legal and economic factors affecting the transfer pricing method selected
• A description of the company’s organizational structure
• A description of the transfer pricing method selected
• Reasons why the method was selected (a “best method” analysis)
• A description of alternative methods, and why they were not selected
• A description of all controlled transactions
• Any internal data used to analyze controlled transactions
• A description of comparables used, how comparability was evaluated, and any adjustments
• An explanation of the economic analysis and projections used to develop the pricing method
• Any material data discovered after the close of the tax year but before filing the tax return
• A general index of the principal and background documents
• A description of the record-keeping system.
Read more about transfer pricing rules here.
Read more about transfer pricing at Asia Pacific Forum.



