Transfer Pricing Documentation Support
Transfer pricing documentation, the master file describing the group's global operations and pricing policy, and local files justifying specific intercompany transactions in each jurisdiction, has to be prepared and kept current for every material related-party transaction, and it's typically assembled under deadline pressure once a year by someone pulling intercompany transaction data, prior year documentation, and functional analysis narratives from several different sources. When actual intercompany transaction volumes or terms shift during the year and the documentation isn't updated to match, the file that gets presented if a tax authority actually requests it can be describing a related-party relationship that no longer matches what's actually happening on the books, which is exactly the kind of gap a transfer pricing audit is built to find.
STARTING PRICE
From €799
Complex tier · Multi-system orchestration, custom logic, and higher-volume or higher-risk processing.
Get a quote →Saves roughly 15-30 hrs per documentation cycle for a group with multiple jurisdictions and transaction types.
How the automation works
We maintain your transfer pricing documentation, master file and local files by jurisdiction, continuously against actual intercompany transaction data rather than reconstructing it once a year, so the documentation on file reflects what's actually happening in the intercompany ledger, not a snapshot from whenever it was last updated. Each local file's described transaction terms are cross-checked against actual recorded intercompany transactions for the period, and any material discrepancy, a transaction volume or pricing that's drifted from what the documentation describes, is flagged for review and update well before an audit or filing deadline. Documentation gaps, a new intercompany transaction type with no corresponding local file, are flagged as soon as the transaction pattern emerges, not discovered retroactively. Benchmarking studies are refreshed on a jurisdiction-appropriate cycle rather than left static for years, since several tax authorities expect comparable-company data to be reasonably current relative to the tested fiscal year, not from whenever the original study was commissioned.
Process flow
- 01
Map documentation to transaction types trigger
Master file and local files are mapped against your actual intercompany transaction types and the jurisdictions each applies to.
- 02
Ingest intercompany transaction data integration
Actual intercompany transaction volume, terms, and pricing are ingested from your financial systems on an ongoing basis.
- 03
Cross-check documentation against actuals ai
Each local file's described transaction terms are cross-checked against actual recorded transactions, flagging material drift between what's documented and what's happening.
- 04
Flag documentation gaps ai
A new intercompany transaction type or relationship without a corresponding local file is flagged as soon as the pattern emerges, not discovered at year-end.
- 05
Assemble current documentation package output
The current, cross-checked master file and local file set is assembled and ready ahead of a filing deadline or an actual audit request.
Inputs
- Intercompany transaction data by entity and jurisdiction
- Existing master file and local file documentation
- Transfer pricing policy and functional analysis
- Jurisdiction-specific documentation requirements
Outputs
- Continuously maintained master file and local files
- Documented-vs-actual transaction discrepancy flags
- New transaction type documentation gap flags
- Audit- and filing-ready documentation package
Works with
Prefer a fully custom build instead of an off-the-shelf integration? We scope both options during your free consultation — most jobs like this one work fine on standard connectors, but higher-volume or non-standard systems sometimes need bespoke API work, reflected in the complex tier.
Where this goes wrong if you get it wrong
- Transfer pricing documentation assembled once a year under deadline pressure tends to describe the intercompany relationship as it was understood at the time of drafting, not as it's actually operating by the time a tax authority requests it a year or two later, and that drift between documented and actual practice is precisely what a transfer pricing audit is designed to surface.
- A functional and risk analysis narrative that hasn't been revisited as a subsidiary's actual functions shift, a distribution entity that's taken on more risk or a different function than the documentation describes, undermines the pricing justification even if the numbers in the local file are internally consistent, documentation has to track actual functions and risk, not just transaction values.
- This tool assembles and cross-checks documentation against your data, it does not set or validate your transfer pricing policy itself, the economic analysis, comparable selection, and arm's-length range determination need to come from your transfer pricing specialists or advisors, not be inferred by the automation.
- A new type of intercompany transaction, a new service arrangement, a new financing structure, that starts flowing through the books without a corresponding local file is a common documentation gap, and it's easiest to catch the moment the transaction pattern first emerges, not months later when volume has already accumulated without supporting documentation.
Frequently asked questions
Does this set our transfer pricing policy or determine arm's-length pricing?
No, the economic analysis and pricing policy come from your transfer pricing specialists or advisors; this maintains and cross-checks the documentation of that policy against actual transaction data.
How does this catch documentation that's fallen out of date?
Local file transaction terms are cross-checked against actual recorded intercompany transactions on an ongoing basis, flagging material drift, rather than only being reviewed once a year at documentation renewal time.
What happens if we start a new type of intercompany transaction?
It's flagged as a documentation gap as soon as the transaction pattern emerges in the data, so a local file can be prepared before volume accumulates without supporting documentation.
Is this built to OECD-aligned master file and local file requirements?
Yes, the documentation structure follows the OECD master file and local file framework most jurisdictions' transfer pricing rules are based on, adapted to jurisdiction-specific requirements where they differ.