Stage three, the record
Transfer pricing documentation
Built from the same structured data the rest of the platform runs on. Not re-gathered each year. Available in hours, not months. Documentation is the stage that should be boring, and it is boring exactly when the two before it have been done properly.
Assembled, not written
A Local File is mostly a description of things already known: the entity, its controlled transactions, the functional analysis, the method chosen and why, the economic analysis, and the financial data.
When those live as data rather than as last year's Word file, the document is assembled and then reviewed, rather than researched and then written.
What a Local File is made of
- Entity overview, from the group structure.
- Controlled transactions, from the design stage.
- Functional analysis, collected once and reused.
- Method selection and the reasoning behind it.
- Economic analysis, from the benchmarking study.
- Financial information, reconciled to the statutory accounts.
Item by item
What sits in Documentation.
Master File
The group level picture: organisational structure, description of the business, intangibles and how they are owned and developed, intercompany financing, and the group's financial and tax positions.
Written once for the group and kept current, rather than rebuilt per jurisdiction.
Local File
The entity level file: the local entity, its controlled transactions, the functional analysis for each, the method and why it was selected, the economic analysis supporting the outcome, and the financial information tying it back to the statutory accounts.
Produced per entity from shared group content plus local specifics, so twelve Local Files are not twelve separate projects.
TP Policy
The document stating how the group prices its intercompany transactions, and the same record the calculations run on. When the policy changes, what changes is the object the engine reads, not only a paragraph in a PDF. The document and the numbers cannot drift apart.
CbCR
Country-by-country reporting for groups above the consolidated revenue threshold, together with the notifications each jurisdiction expects and the deadlines attached to them.
Business restructuring memos
When something moves, functions, assets, risks or people, the file needs to explain what moved, what it was worth, and whether an exit charge arises. These memos are written at the time rather than reconstructed two years later under audit, which is the only time they are genuinely persuasive.
Standardised across jurisdictions
Twelve Local Files should not read like twelve different firms wrote them, because to a tax authority comparing notes with a treaty partner, that is exactly what inconsistency looks like.
Documentation is produced to one structure and one vocabulary, with local requirements layered on top rather than starting each file from a local template.
Audit defence
We design, implement, document and defend transfer pricing policies. The fourth verb is the one that changes how the first three are done.
A file built to be defended keeps the working, not just the conclusion: the comparables that were rejected and why, the version of the agreement in force for the period under review, the information request that produced a fact and the date it arrived. When an enquiry opens on a year nobody currently in the team worked on, that record is the difference between a defence and a reconstruction.
