Value Proposition: The Transfer Pricing documentation pack transforms the requirements of the Master File / Local File into a reviewable “delivery inventory”: Scope → Checklists → Document Request List → Timeline → Evidence Index → TP Pack (Final) instead of relying on late compilation at the time of review that does not substantiate data sources or close on the company’s files.

In 20 seconds: What will you receive?

• Master File Checklist with organized items + “required evidence” for each item.
• Local File Checklist for each entity/country linked to related party transactions and GL.
• Document Request List (DRL) ready for dispatch + Owner/Deadline/Status for each file.
• Timeline evidencing data collection/review/approval dates instead of last-minute delays.
• Evidence Index linking each checklist item to its folder/reference within the pack.
• Exceptions Log for missing items (missing contract/unavailable data/missing report) and closure plan.
• Sign-off (Version/Date/Reviewer/Approver) to confirm the “Final” version for delivery.

CTA related to deliverables: Receive Master/Local Checklists + Timeline + Evidence Index to prepare a deliverable TP Documentation Pack.

Suitable for

• Tax Manager / Head of Tax who wants to manage Master/Local file requirements as a clear delivery list.
• Financial Controller needing to link intercompany transactions to GL and prepare evidence before review.
• Group Finance managing multiple entities and wanting to standardize the request and delivery process via Timeline.

Not suitable for

• Those seeking Benchmarking or determining margin/mark-up “as a final value” without operational/cost data or without internal pricing policy.
• A company with no actual intercompany transactions/related parties (there will be no impactful documentation scope).

Without the pack / With the pack (Quick Comparison)

Before use: 5 symptoms appearing in Transfer Pricing documentation

• No actual Master/Local file; there are “points” without attachments or evidence of data sources.
• Intercompany contracts or service appendices are incomplete/outdated within a single file.
• Intercompany transactions cannot be traced from GL to agreement/type of transaction (services/royalties/loans).
• Delayed data collection due to lack of Timeline or Owner for each item (Finance/Tax/Legal/Operations).
• Multiple versions before delivery (no Version control/Sign-off) leading to loss of the reference version during review.

Transfer Pricing: Implementation Method (3 Steps Without Gaps)

Step 1: Preparation and Report Collection

• Define the scope of Related party transactions: Services/Goods/Royalties/Loans/Management Fees…
• Extract TB/GL for relevant accounts + Subledger reports (AR/AP) if necessary.
• Compile agreements/contracts + group structure + list of legal entities.

Step 2: Checklists + DRL + Timeline

• Fill out the Master File checklist and Local File checklist and specify the required evidence for each item.
• Issue the Document Request List and assign Owner, Deadline, and Status for each file.
• Update the Exceptions log for missing items and determine the closure decision (collect/replace/documented exception).

Step 3: Evidence Index + TP Pack + Sign-off

• Compile documents into the TP Documentation Pack with a fixed folder structure (Master/Local/Contracts/GL extracts…)
• Build an Evidence index linking each checklist item to its attachment/reference and file path.
• Close the final version via Sign-off (Version/Date/Reviewer/Approver) to establish the reference version for delivery.

Pack Components (Clear Inventory)

1. Master File Checklist
   • Practical Purpose: Transform Master file requirements into actionable items with specified required evidence.
   • When to Use: Annually at the group level + when structure/activity changes.
   • Resulting Evidence: Completed checklist + links/references for each attachment within the pack.
2. Local File Checklist (for each entity/country)
   • Practical Purpose: Adjust documentation of transactions at the entity level and link them to GL and agreements.
   • When to Use: Annually for each Legal Entity within the TP scope.
   • Resulting Evidence: Local checklist for each entity + reference for transactions/reports/contracts.
3. Document Request List (DRL)
   • Practical Purpose: Inventory of document requests and specify who prepares them and when, instead of late requests at the time of review.
   • When to Use: At the beginning of the documentation cycle + when adding a new item/exception.
   • Resulting Evidence: DRL with Owner/Deadline/Status/Notes for each file.
4. Timeline & Responsibilities
   • Practical Purpose: Establish delivery points (Collection → Review → Approval) and reduce overdue items before Year-End.
   • When to Use: Throughout the year/last quarter until the final version is issued.
   • Resulting Evidence: Timeline of execution status + list of delay risks.
5. Evidence Index
   • Practical Purpose: Link each Master/Local file item to the supporting document (file name/path/report reference/GL extract).
   • When to Use: Before final closure and before any delivery for review/audit.
   • Resulting Evidence: Index that reduces search time and establishes Traceability.
6. Exceptions Log
   • Practical Purpose: Compile missing or conflicting items and document the resolution decision.
   • When to Use: Throughout the documentation cycle until closure.
   • Resulting Evidence: Exceptions log with decision/owner/closure date.
7. Sign-off Sheet
   • Practical Purpose: Establish the reference version for documentation (Version control) and who reviewed and approved.
   • When to Use: When issuing the annual final version.
   • Resulting Evidence: Sign-off page preventing multiple versions within the team.

CTA related to deliverables: Master/Local Checklists + DRL + Evidence Index + Sign-off as a documentation and delivery package.

What should be included in the delivery?

• 01 – Scope Pack: List of entities + Map of intercompany transactions + Classification of transaction types (Services/Goods/Royalties/Loans).
• 02 – Master File Checklist (Completed): Master file items + closure status + evidence reference.
• 03 – Local File Checklists (Completed): File/Checklist for each entity/country within scope.
• 04 – Intercompany Agreements Folder: Contracts/Agreements + Appendices + Effective Dates + Any Updates.
• 05 – GL/TB Extracts: TB/GL for relevant accounts + any AR/AP details or internal invoice reports.
• 06 – Transaction Listings: Listings of related party transactions by type (Invoices/Charges/Payments) with reference.
• 07 – Allocation/Cost Support: Cost sources/Allocation keys/Charge-out basis (if services are Cost plus).
• 08 – DRL & Timeline: Document request list + responsibilities + deadlines + execution status.
• 09 – Evidence Index: Index linking each Master/Local item to its attachment and path.
• 10 – Exceptions Log: Open/closed items + resolution decision and justification.
• 11 – Sign-off: Final version (Version/Date/Reviewer/Approver) as a delivery reference.

After Implementation (Two Key Outcomes)

• Operational Outcome for the Team: The TP cycle transforms into actionable tasks with an owner and deadline (DRL + Timeline) instead of chasing documents at Year-End.
• Control/Audit Outcome (Evidence & Traceability): Each Master/Local file item has evidence and an index linked to the GL, and the final version has a Sign-off; reducing reassembly during the audit.

FAQ — Questions Before Purchase

Is the pack suitable for any country?

It is suitable as an organizational and delivery framework (Master/Local checklists + evidence). Final detailed requirements vary by country and group policy; the template allows for item alignment.

Does it include Benchmarking or margin/mark-up determination?

No. This is a documentation and requirements management pack. Benchmarking and margin/mark-up determination typically require separate studies and data sources.

Is it suitable for a multi-entity group?

Yes. The Master file is at the group level, and the Local file is for each Legal Entity, with a Timeline and DRL for distributing responsibilities.

What is the minimum data required to start?

A map of related party transactions + contracts/agreements + TB/GL for relevant accounts + transaction listings (invoices/charges/payments) if available.

Does it include linking figures to the GL?

Yes, by including GL/TB extracts in the delivery and linking them in the Evidence index as a source of the figures used in documentation.

Is it suitable as a delivery file for reviewers or audits?

It prepares an organized delivery file (evidence index + sign-off). The audit outcome depends on the quality of data and the pricing policy applied, not just on the template alone.

Can it be used throughout the year, not just at Year-End?

Yes. It is best to operate the DRL and update attachments and exceptions continuously to reduce Year-End gaps.

Does it eliminate the need to write the Master/Local file as text?

It does not automatically write the text, but it provides the structure for requirements, evidence, and delivery folders; the final text writing depends on your team/consultant and reporting framework.

Ready to finalize TP documentation as a delivery pack?

You will receive: Master/Local Checklists + DRL + Timeline + Evidence Index + Exceptions Log + Sign-off to prepare the Transfer Pricing file before the audit.