Local File4 min
From Local File to review record
Why the conclusion, its sources, assumptions and reviewer decisions should remain connected after filing.
Read analysisResources
Transfer pricing resources
Practical frameworks and analysis for Local Files, method selection, benchmarking and transaction-level review.
Resource hubs
Start with the TP workstream.
Three routes cover the work behind most Local File positions.
01
Local File & documentation
Review scope, evidence, financial support, assumptions and annual changes before drafting is finalised.
Explore02
Methods & benchmarking
Document method selection, tested-party logic, comparability criteria and the final benchmarking record.
Explore03
Intercompany transactions
Apply the analysis to services, distribution, manufacturing, software and IP fact patterns.
ExploreTransaction guides
Common TP fact patterns.
Start from the operating model, then define the method, evidence and review points.
Transactions
Intercompany services
Scope the service, benefit evidence, cost pool, allocation key, markup and Local File support.
Open resourceTransactions
Limited-risk distribution
Test the operating model against actual risk control, commercial conduct, method selection and market outcomes.
Open resourceTransactions
Contract manufacturing
Analyse production functions, capacity, inventory, quality risk, cost base and the reliability of a cost-based return.
Open resourceTransactions
Software and IP transactions
Connect legal ownership, DEMPE functions, risk control, funding and the selected pricing approach.
Open resourceMethods and controls
Practical frameworks for day-to-day TP work.
Guide
Selecting a transfer pricing method
A disciplined route from accurately delineated transaction to CUP, cost plus, RPM, TNMM or profit split.
Open resourceFramework
Tested-party decision sheet
A compact decision record for functions, risks, data reliability, segmentation and the availability of comparables.
Open resourceFramework
Benchmarking review sheet
A review structure for search strategy, screening decisions, comparability, PLI selection and final range.
Open resourceLocal File controls
Make the documented position reviewable.
Framework
Local File review framework
A structured review sequence for transaction scope, functional analysis, method selection, financial support and open evidence.
Open resourceFramework
Source and assumption register
A practical register connecting each material TP statement to its source, owner, status and review decision.
Open resourceGuide
Annual Local File roll-forward
A controlled update process that distinguishes unchanged positions from facts, figures and judgments that require fresh review.
Open resourceRecent analysis
The work behind a TP position.
Methods4 min
Method selection before benchmarking
Why a database search should not begin until the transaction, tested party and decision criteria are defined.
Read analysis
Transactions4 min
One dossier, one decision record
A compact operating model for keeping transaction facts, analysis, sources and senior review in one handover.
Read analysisNeed a starting point?
Bring one transaction and one review question.
Dublon proposes the scope, required evidence, output and review boundaries before the work starts.