Transfer pricing documentation services

Transfer pricing documentation consultants

Our transfer pricing documentation consultants support multinational groups in preparing clear, defensible, and regulator-ready documentation across jurisdictions. We combine technical precision with commercial insight to ensure Master and Local Files accurately reflect your value chain, functional profile, and intercompany arrangements.

We focus on aligning policy with implementation, strengthening audit readiness, and reducing exposure to penalties or disputes. Through practical, efficient processes and robust economic analysis, we deliver documentation that stands up to scrutiny while remaining proportionate to your business.

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Transfer Pricing Documentation

Transfer pricing documentation requires more than technical compliance. It demands economic depth, regulatory awareness, and a practical understanding of how tax authorities assess intercompany arrangements.

Master File Preparation

The Master File provides a high-level overview of your multinational group’s global operations, transfer pricing policies, value chain, and intangible ownership structure. It ensures OECD-aligned transfer pricing documentation consistency across jurisdictions and supports coordinated tax authority review.

We prepare comprehensive Master Files covering:

• Group organisational structure

• Global value chain analysis

• Intangible assets and DEMPE functions

• Intercompany financing arrangements

• Group transfer pricing framework

The Master File establishes a consistent and defensible global compliance position.

The Local File documents material intercompany transactions within a specific jurisdiction, including FAR analysis, transfer pricing method selection, benchmarking, and financial support. It demonstrates that local transactions comply with the arm’s length principle.

Our Local File services include:

• Identification of controlled transactions

• Functional, Asset & Risk (FAR) analysis

• Selection of appropriate transfer pricing methods (TNMM, CUP, Cost Plus, RPM)

• Economic benchmarking studies

• Financial analysis and supporting schedules

Each Local File is tailored to jurisdiction-specific thresholds and regulatory requirements.

Local File Documentation

Country-by-Country Reporting (CbCR)

Country-by-Country Reporting provides tax authorities with a breakdown of revenue, profit, employees, and taxes paid across jurisdictions. CbCR enhances transparency and allows authorities to assess transfer pricing risk at a global group level.

We assist with:

• CbCR data preparation and validation

• Alignment with Master File and Local Files

• Threshold assessment and reporting obligations

• Risk exposure review

Consistency across documentation layers reduces audit exposure and strengthens compliance.

Transfer pricing benchmarking supports intercompany pricing by identifying comparable companies or transactions and establishing arm’s length ranges. Proper benchmarking is essential for defending margins, mark-ups, and pricing methodologies during tax audits.

We conduct independent benchmarking analyses using recognised financial databases, covering:

• Comparable company searches

• Margin and mark-up analysis

• Interquartile range determination

• Documentation of selection criteria

• Sensitivity and robustness testing

Our benchmarking studies are structured for audit defensibility and regulatory compliance.

Transfer Pricing Benchmarking Studies

Other transfer pricing documents

Transfer pricing documentation goes beyond the statutory requirements. It's important to maintain records for external and internal discussions, decision-making, and agreements.

Explore our comprehensive services focused on value chain creation and practical implementation.

TP Intercompany Agreements (ICA)

Binding agreements between tax authorities and international companies that set the transfer pricing methodology for specific transactions, aiming to reduce disputes and ensure tax compliance.

TP Advance Pricing Agreements (APA)

Documents governing the legal and commercial relationships between the different entities ensuring that transactions are conducted under pre-agreed terms and follow TP policy.

Transfer pricing defence files for audits & disputes

Comprehensive documentation prepared to support transfer pricing practices, choices or changes during audits or disputes with tax authorities.

TP Policy For Internal & External use

Captures the group TP structure and methodology used, serves as a blue-print for intercompany arrangement. For internal & external use.

Transaction based documentation

Detailed records and analyses that support the pricing of specific intercompany transactions, demonstrating compliance with tax regulations.

Business Case for Change

Outlines the rationale and strategic justification for modifying transfer pricing practices or policies. It typically includes an analysis of the anticipated benefits, costs, risks, and alignment with overall business objectives.

TP compliance trusted by senior executives

Here's what our clients think of the work we deliver for them. We deliver positive and profitable outcomes for C-Level executives across cross-border expansion and transfer pricing.

The team at iVC Consulting is young but nevertheless very experienced and knowledgeable. They quickly obtained a good understanding of our quite complex global structure and resulting needs in relation to a global transfer pricing policy. They approached the problem as if they were internal employees of Docplanner - in a very pragmatic and efficient way. I was also impressed by their modeling skills. Highly recommend, especially for high-growth tech companies.

Peter Bialo
CFO and Board Member
DocPlanner

Transfer Pricing and Beyond! If you are looking for a quality service and advice that works in practice, iVC Consulting should be your choice. Extensive professional knowledge, knowing its client, practical approach - that's what makes a difference.

Agnė Petkevičiūtė
Director of Tax
Vinted

★★★★★

★★★★★

Your transfer pricing journey

Scaleup support calls

We guide you through the challenges regarding crossborder scaling with support calls that deliver.

• Crossborder advice

• Transfer pricing advice

• Actionable follow-ups

• Accountability

Build your value with iVC

Value chain consulting

Within the first three months, our team identifies high-priority workflows you need support on.

• Actionable outcomes

• Your value chain creation

• Value-derived from knowledge

• Focus on scaling

iVC partnership

Of engagements started, 80% of clients make iVC their trusted advisor for global expansion.

• Long-term partnership

• Strategic alignment

• Trusted advisory

• Data focused

Get in touch

Frequently asked questions

How does iVC Consulting help with transfer pricing documentation?

We prepare tailored Master and Local Files, perform benchmarking and comparability analyses, document functional and DEMPE profiles, and ensure alignment between policy and implementation to create defensible documentation.

What is included in iVC’s transfer pricing documentation services?

Our services include functional interviews, transaction mapping, economic analysis, benchmarking, drafting compliant reports, reviewing intercompany agreements, and coordinating multi-country documentation requirements.

How does iVC’s DID² approach support documentation?

Our Design, Implementation, Documentation, and Defence framework ensures policies are clearly documented, consistently applied, and supported by robust evidence - providing a strong foundation in the event of audit or enquiry.

How can I get started with iVC on transfer pricing documentation?

You can reach us by booking a meeting with us or just write an email to hello@ivc-consulting.com. We’ll assess your needs and outline a compliance strategy.

What is transfer pricing documentation?

Transfer pricing documentation records how intercompany transactions are priced and demonstrates that they meet the arm’s length standard. It typically includes Master and Local Files, functional analyses, benchmarking studies, and supporting financial data.

Why is transfer pricing documentation important?

Robust documentation reduces the risk of penalties and adjustments by evidencing compliance with local and international regulations. It strengthens audit defence, supports consistency across jurisdictions, and helps prevent double taxation.