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.

Our power of choice is untrammelled and when nothing prevents our being able to do what we like best, every pleasure is to be welcomed and every pain avoided. But in certain circumstances and owing to the claims of duty.

icon png

Background Checks

These cases are perfectly simple and easy to distinguish. In a free hour when our power.

Transfer pricing documentation is a set of documents and information that multinational companies are required to maintain to support the transfer prices used in their intercompany transactions. Transfer prices are the prices at which goods, services, or intangible assets are transferred between related companies or entities within a multinational group.

The purpose of transfer pricing documentation is to provide evidence that the transfer prices used in intercompany transactions are consistent with arm's length principles. Arm's length principle is the basis for determining the appropriate transfer prices between related companies in a multinational group, which requires the prices to be similar to the prices that unrelated companies would charge for similar transactions.

There are different types of transfer pricing documentation requirements in different countries, and the level of detail required varies. However, the most common documentation requirements include a master file, a local file, and a country-by-country report.

Transfer pricing documentation is essential for multinational companies to ensure compliance with tax laws and avoid potential penalties and disputes with tax authorities. It is also useful for providing transparency and clarity about intercompany transactions and transfer pricing policies to stakeholders such as investors, regulators, and customers.

icon png

Profile Assessments

Indignation and men who are so beguiled and demoralized by the charms blinded.

icon png

Position Description

Trouble that are bound to ensue and equal blame belongs those who fail in their duty.

HR Functions

Nothing prevents our being able to do what we like best every pleasure is to be welcomed & every pain avoided certain circumstances.

Open Communication

Equal blame belongs to those who fail in their duty through weakness same duty.

Sharing a Vision

Business it will frequently occur that pleasures have to be repudiated.

Recognizing Employee

Holds in these matter to this principle selection he rejects pleasures to secure.