Transfer pricing documentation — evidence list
The evidence behind a transfer-pricing file — not the report, the material that makes the report true.
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The evidence behind a transfer-pricing file — not the report, the material that makes the report true.
The document pack
- Intercompany agreements for every related-party transaction, signed and dated
- Invoices and settlement records showing what was actually charged and paid
- Time records, deliverables or correspondence evidencing services rendered
- Organisation charts and role descriptions for the people performing the functions
- Board and management minutes showing where decisions were taken
- Segmented financial data for the tested party, on a consistent basis
- The benchmarking search strategy, including the rejection log
- Any prior authority correspondence on pricing
Why each of these is asked for
Documentation prepared after a query does not satisfy a contemporaneous-documentation requirement, and a report that cannot be reconciled to the accounts is worse than a short one that can. The rejection log and the evidence of services actually rendered are the two items auditors reach for first.
Your next step
Send what you have and we will tell you what is missing. A complete pack is usually the difference between a filing that takes a fortnight and one that takes a season. Bring last year's returns and we will tell you what is missing.
Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
FBAR transfer between accounts, in practice
If you came here for FBAR transfer between accounts, this is where it is dealt with. The subject is transfer pricing documentation, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.
The difference a dedicated cross-border team makes
One team, not two firms billing separately
You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.
We say early if it is not our work
If a file needs something this practice does not do, you hear that at the start rather than after a bill.
Late and missed years are ordinary work
An unfiled history is not a reason to wait longer. We assess what is still open and what relief the delay attracts before the first return goes in.
A named reviewer on every file
Every page on this site and every file we deliver says which practitioner reviewed it — a person, not a team inbox.
Files that look like this one
Management fee supported for open years while agreements were put in place
A group had charged a head office fee to its Canadian subsidiary for years with no written agreement. For the current year we drafted an agreement reflecting how the arrangement actually operated, signed and dated before the next charge. For the open years the work was different: assembling the correspondence that had set the terms, the settlement records showing what was paid, and the deliverables produced. The engagement produced a documented basis for the past years grounded in evidence that existed at the time, and a signed agreement going forward, rather than one document purporting to cover both.
Service charges evidenced with deliverables after an information request
An information request asked what the group's support charge had bought. The company had an allocation key and an invoice and nothing else. We worked with the teams involved to collect the outputs of the year: the reports produced, the system implementations supported, the approvals given, and the email trail between those who asked for the work and those who did it. The engagement produced a response evidencing the activity with material created at the time, and a records practice that keeps deliverables with the charge rather than in the mailboxes of individuals.
Segmented accounts built for a tested party inside a single legal entity
The entity ran a distribution business and a contract development function under one set of statutory accounts, and only the distribution activity was being tested. The margin in the report could not be traced to anything the company filed. We built a segmentation, documented the allocation keys for shared costs and the head count basis behind them, and reconciled the segments back to the statutory result. The engagement produced financial data the analysis could sit on, a reconciliation a reviewer can follow, and a basis the finance team now prepares at each year end.
Benchmarking search rebuilt with its rejection reasons retained
An inherited file presented a set of comparable companies with no record of how they had been found. The result may well have been defensible, but there was no way to show it. We reran the search, recording the database and version, the screens in the order applied, and the reason each candidate was rejected on manual review. The engagement produced a comparable set with a complete trail behind it, and a search strategy the group can refresh on the same basis in later years instead of starting again from nothing.
Decision-making mapped where contracts and conduct had drifted apart
The intercompany agreements placed risk with an entity whose board minutes showed no decisions of that kind being taken. A functional analysis written from the contracts alone would have said something the rest of the file contradicted. We read the minutes, the delegated authority schedules and the organisation charts, and established where the relevant decisions were actually made and by whom. The engagement produced a functional analysis consistent with the evidence, and a list of the places where either the contracts or the conduct needed to change before the next year closed.
Prior authority correspondence located and reconciled to current pricing
A group came to us unaware of an exchange its predecessor had had with a tax authority about the same transactions. The correspondence surfaced in an archived file during document collection. It set out a basis the group had since drifted away from without ever deciding to. The work consisted of reading what had been said, comparing it with the current arrangement, and setting out the differences and the reasons for them. The engagement produced a documentation file that addresses the earlier position directly rather than leaving the authority to raise it.
A Margin Defended With a Benchmarking Set That Fits the Facts
A comparables set is only as good as the screening behind it, and a rejected set takes the margin with it. The study selects the tested party first, screens on function rather than on industry code, and records why each comparable survived.
Read how this one runsA US Filer Married to Someone Outside the System
Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.
Read how this one runsAll case studies — every published engagement in one place.
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Investment Funds & Holding Companies
Holding structures live or die on treaty access, beneficial ownership and substance — the MLI's principal-purpose test now sits over every arrangement.
A holding structure is only as good as its reporting. Foreign affiliates, accrued passive income and distributions each carry their own return, and the penalties on those attach to the form rather than to any tax being owed — so a structure that saves tax can still cost money if the information returns are late.
- Treaty access & PPT reviews
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- Withholding-efficient routing
- Governance & substance
