Documentation · Service 02
Transfer pricing documentation that holds up when it needs to
Intercompany transactions between related parties in different countries require documentation that can withstand scrutiny. Margyn prepares transfer pricing analyses and local-file reports built around your actual transactions — not off-the-shelf frameworks applied without context.
What this delivers
Documentation prepared to support your intercompany positions — not just to file
When tax authorities examine intercompany transactions, the question they're asking is straightforward: would unrelated parties have agreed to these terms? The documentation that answers that question needs to be grounded in a genuine functional analysis, supported by relevant benchmarking, and prepared with the specific jurisdiction's requirements in mind.
Margyn prepares transfer pricing documentation that addresses those questions directly — built from the specifics of your transactions, your functions, your assets, and your risks, rather than adapted from a generic template.
Functional analysis
A detailed analysis of the functions performed, assets used, and risks assumed by each related party in the transaction — the foundation of any credible transfer pricing position.
Benchmark study
A comparables search and economic analysis that supports the arm's-length nature of the pricing applied to your intercompany transactions.
Local-file report
A jurisdiction-specific report prepared in accordance with OECD guidelines and the documentation requirements of the relevant local tax authority.
A position worth understanding
Intercompany transactions without proper documentation carry a risk that tends to grow over time
Companies with related-party transactions across two or more countries are generally required to maintain contemporaneous documentation that justifies the pricing used. In practice, many businesses either don't have documentation at all, or have documentation that was prepared without a genuine functional analysis — which means it wouldn't hold up if examined.
The challenge is that transfer pricing exposure tends to be quiet until it isn't. Transactions accumulate over multiple years, and when an authority does examine them, the question isn't just about the current year. Gaps in documentation can make a routine review considerably more complicated.
Good transfer pricing documentation isn't about making a bold claim — it's about building a well-evidenced position that can be explained clearly, step by step, to someone who wasn't involved in the original transactions.
That's what this engagement is designed to produce: documentation prepared with that level of rigour, specific to your transaction types and the jurisdictions in scope.
The approach
How Margyn prepares transfer pricing documentation
Each engagement begins with a review of the transaction types and volumes in scope. The scope and structure of the documentation are agreed from that starting point — not assumed in advance. What follows is a methodical process built around your specific intercompany arrangements.
Transaction review
We identify and categorise the intercompany transactions in scope — services, goods, financing, IP licensing — and establish the volumes and terms that will form the basis of the analysis.
Functional analysis
We build the FAR analysis — functions, assets, risks — for each entity participating in the transactions, drawing on information from your team about how the business actually operates.
Benchmarking
We identify the most appropriate transfer pricing method for each transaction category and carry out a comparables search to support the arm's-length range used.
Local-file preparation
We prepare the local-file report in the format required by the relevant jurisdiction, referencing the functional analysis and benchmark study as supporting evidence.
What working together looks like
A collaborative process that respects your time while doing the work thoroughly
Most of the analytical work happens on our side. You'll be involved at the points where your knowledge of the business is needed — not throughout. The process is structured to minimise the burden on your team while producing documentation that reflects genuine understanding of the transactions.
Transaction scoping call
We discuss which intercompany transactions are in scope, the jurisdictions involved, and what documentation currently exists — or doesn't. This informs the engagement plan.
FAR interview and data review
We work through the functions, assets, and risks of each entity with your team — typically via a structured conversation — and review relevant financial and contractual information.
Benchmarking and methodology
We carry out the comparables search and economic analysis. This phase is largely internal — we'll flag any questions that arise about your transaction terms or pricing rationale.
Report delivery and review
You receive the complete documentation package and a session to walk through the findings, conclusions, and the arm's-length range established for each transaction type.
Investment
Scope defined first, fee confirmed before work starts
Transfer pricing documentation engagements vary in complexity depending on the number of transaction types, the jurisdictions in scope, and the state of existing documentation. The fee below reflects a standard engagement. Scope is confirmed following the initial review, and the final fee is agreed in writing before work begins.
Service investment
$8,000 USD
Flat fee · Defined scope · Confirmed before engagement starts
Engagements covering a larger number of transaction categories or additional jurisdictions are scoped individually. The fee is always agreed before the engagement commences.
What's included
Transaction scoping review
Identification and categorisation of intercompany transactions to be covered by the documentation.
Functional analysis (FAR)
Full analysis of functions performed, assets used, and risks assumed by each related party.
Benchmark study and comparables search
Economic analysis establishing an arm's-length range for each transaction category in scope.
Local-file report
Jurisdiction-specific documentation prepared in accordance with OECD guidelines and local requirements.
Delivery review session
Walkthrough of the completed documentation package, including conclusions and the arm's-length ranges established.
Post-delivery clarifications
Follow-up questions addressed within a reasonable period after the documentation is delivered.
Methodology
The standards our documentation is built to
OECD Transfer Pricing Guidelines
All work is prepared in line with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which form the basis for transfer pricing rules in most jurisdictions.
Jurisdiction-specific requirements
Local-file reports are prepared with reference to the specific documentation requirements of each jurisdiction in scope — not applied generically from the OECD standard alone.
Most appropriate method selection
We select the transfer pricing method — CUP, cost plus, TNMM, and others — most appropriate for each transaction type, based on the functional profile and available comparables.
Contemporaneous preparation
Documentation is prepared to reflect the period under review — not reconstructed after the fact. Timelines are agreed at the outset so the documentation is ready when it's needed.
Typical timeline
Engagements typically run six to ten weeks from confirmed scope to delivered documentation, depending on the number of transaction types in scope and the availability of your team for the FAR interview. Complex structures with multiple transaction categories may require additional time, confirmed upfront.
Our commitment
Documentation you can rely on — and understand
Transfer pricing documentation is only useful if it accurately reflects how your business works and can be explained coherently to a third party. We're committed to both — and to producing documentation that your team and your local advisors can engage with confidently.
Confirmed scope and fee
Engagement scope, deliverables, and fee are agreed in writing before any work begins.
Built on your information
The functional analysis reflects how your business actually operates — not assumptions made from outside.
Revision if needed
If any aspect of the documentation requires clarification or adjustment after review, we address it as part of the engagement.
Getting started
The path to completed documentation is straightforward from here
Send a brief description of your situation — the jurisdictions involved, the nature of the intercompany transactions, and whether any documentation currently exists. We'll come back to you about next steps.
Send your message
Describe your situation briefly — jurisdictions, transaction types, current documentation status. No formal brief needed.
Scoping conversation
We discuss the transactions, volumes, and jurisdictions to define the scope and confirm what documentation will cover.
Engagement confirmed
Scope, deliverables, and fee agreed in writing. Work begins at a point that suits your timeline.
Transfer Pricing Documentation
Intercompany transactions that can be explained and supported — starting here
Tell us about your transactions, the countries involved, and what documentation you currently have. We'll take it from there.
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