Guide · Local File · 3 min
Transfer pricing: the question behind the documentation
What transfer pricing concerns, why the facts matter and how a defined question becomes a documented position.
01
What is being priced?
Transfer pricing concerns the prices and conditions of transactions between associated enterprises. These may involve goods, services, loans or the use of intellectual property. The arm's length principle asks whether the conditions are consistent with those independent enterprises would agree in comparable circumstances.
02
Start with the business question
For a services assignment, for example, first establish who performs the work, who receives it and what information supports the charge. An agreement is a starting point; the analysis also needs to reflect how the parties operate in practice.
A useful brief identifies what the client needs to resolve, the period concerned and the intended use of the work. This prevents a documentation exercise from drifting away from the question it was meant to answer.
03
What a reviewer needs to understand
- The transaction and each party's actual role.
- The reasoning behind the method and its application.
- The information supporting the conclusion and any unresolved facts.
04
Where Dublon contributes
Dublon helps professional firms turn the agreed question and available information into an analysis and documentation for review. The assignment defines the output and responsibilities; the firm's review and discussion with the client remain part of the process.
Further reading
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