Transfer Pricing Documentation services comprise the preparation of 3-tier documentation, i.e. Local File, Master File and Country-by-Country Report ('CbCR'). We support consultants/ advisors in the preparation of documentation. Further, we also directly service multinational companies to comply with documentation requirements.
How it Works
For Multinational Companies:
- We will analyse your existing Transfer Pricing Documentation and related data;
- Based on the analysis, we identify incremental data points required to prepare the Local File and Master File for the current year;
- If required, we will conduct functional interviews to understand the transaction and business operations in general with relevant personnel from your team;
- We will select the appropriate transfer pricing method and undertake benchmarking analysis using a globally renowned database;
- We draft the Local File and Master File and share the first draft for your review;
- We discuss your review comments and observation and finalise the document;
- If applicable, we support the preparation of CbCR; and
- In the subsequent year, we roll forward the Local File and Master File to the next financial year.
For Consultants/ Advisors
TPNOMIX would leverage the existing Local File and Master File available with the consultant. The scope would include the following:
- Preparing Company Overview, Group Overview, Management and Ownership structure. For certain information, we will rely on the client's website or reference website
- leveraging on function, assets and risk analysis from the previous year's Local File provided by the consultant;
- using/ relying on the functional interview notes prepared by the consultant for any new or existing intercompany transactions and basis it drafting the functional analysis;
- documenting the selection of the tested party, most appropriate transfer pricing method, and Profit Level Indicator ('PLI') (including computation of PLI); and
- Review and finalisation of the Local File with the relevant personnel of the consultant.
