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
Understand transfer pricing and the documentation behind it. Find guidance for your transaction, analysis or next 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
TP methods & analysis
Understand the method, functional profile and evidence supporting a transfer pricing position.
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.
Read the guideTransactions
Limited-risk distribution
Test the operating model against actual risk control, commercial conduct, method selection and market outcomes.
Read the guideTransactions
Contract manufacturing
Analyse production functions, capacity, inventory, quality risk, cost base and the reliability of a cost-based return.
Read the guideTransactions
Software and IP transactions
Connect legal ownership, DEMPE functions, risk control, funding and the selected pricing approach.
Read the guideMethods 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.
Read the guideFramework
Tested-party decision sheet
A compact decision record for functions, risks, data reliability, segmentation and the availability of comparables.
Open the frameworkLocal 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 the frameworkFramework
Source and assumption register
A practical register connecting each material TP statement to its source, owner, status and review decision.
Open the frameworkGuide
Annual Local File roll-forward
A controlled update process that distinguishes unchanged positions from facts, figures and judgments that require fresh review.
Read the guideGuide
Preparing TP documentation for professional review
How accountants and advisory firms can organise a defined TP assignment before senior review, while keeping their methodology, template and client relationship in place.
Read the guideGuide
Transfer pricing: the question behind the documentation
What transfer pricing concerns, why the facts matter and how a defined question becomes a documented position.
Read the guideGuide
Local File and Master File: how the documents fit together
Understand the group-wide context, the local transaction analysis and the checks that connect them.
Read the guide
Need a starting point?
Bring one transaction and one review question.
Dublon proposes the scope, required evidence, output and review boundaries before the work starts.