Transfer Pricing

Information Request
Checklist (v 2.0)
Standard List Additional / Follow-up Items
List of intercompany transactions Previous year(s) TP documentation
Filed TP Forms (if any) Annual Financial Statement(s) of the company
Intercompany agreements Annual Financial Statement(s) of the counterparty
Invoice samples Information about internal comparable transactions
Consolidated annual financial statements of the group Segmented/Transactional P&Ls
Masterfile and CbCR (Country-by-Country Report) Organizational charts
TP policy documents Ownership structure
TP audit history information

Industry reports

Any Advanced Pricing Agreements (APAs)

Interviews and Communications

Interviews with key employees
Internal memos/emails/policies Credits to
Borys Follow on
Transfer Pricing Information Request Checklist (v 2.0)
Ulanenko LinkedIn!
List of
Intercompany
Transactions
A list detailing transactions
between related entities within
the same group

Why Is It Requested?
To understand the nature and volume of transactions between related parties

How to Help Client Get It?

Help the client to extract this information from their financial or ERP systems

Transfer Pricing Information Request Checklist (v 2.0)

01
Filed
TP Forms
Forms related to transfer
pricing that the company has
filed with tax authorities

Why Is It Requested?
To assess the company's current transfer pricing policies and practices and
ensure consistency

How to Help Client Get It?

Advise the client on which forms are needed and help them retrieve these from
their tax department or tax service provider

Transfer Pricing Information Request Checklist (v 2.0)

02
Intercompany
Agreements
Contracts between related
entities within the same group

Why Is It Requested?
These documents lay out the terms and conditions of intercompany transac-
tions

How to Help Client Get It?

Request these from the client's legal or contracts department

Transfer Pricing Information Request Checklist (v 2.0)

03
Invoice
Samples
Examples of invoices for
intercompany transactions

Why Is It Requested?
To understand the pricing and billing practices for intercompany transactions.
Invoices may contain other useful information

How to Help Client Get It?

Request these from the client's finance or accounting department

Transfer Pricing Information Request Checklist (v 2.0)

04
Consolidated
Annual Financial
Statements of
the Group
The consolidated financial
statements of the parent
company and its subsidiaries

Why Is It Requested?
These provide an overview of the financial performance of the entire group, as
well as provide additional context

How to Help Client Get It?

These should be readily available from the client's finance or accounting
department. Search Internet for public companies.

Transfer Pricing Information Request Checklist (v 2.0)

05
Masterfile and
CbCR (Country
by-Country
Report)
Comprehensive reports of the
multinational company's global
business operations and
transfer pricing policies

Why Is It Requested?
This gives a high-level overview of the company's global business operations and
transfer pricing policies

How to Help Client Get It?

The client’s tax or transfer pricing managers should have these reports (if they
are within the scope).

Transfer Pricing Information Request Checklist (v 2.0)

06
TP Policy
Documents
Documents that outline the
company's policies on transfer
pricing

Why Is It Requested?
These policies provide the rationale for the company's transfer pricing methodol-
ogies

How to Help Client Get It?

Request these from the client's tax or transfer pricing manager; if not, check
with the finance department

Transfer Pricing Information Request Checklist (v 2.0)

07
TP Audit
History
Information
Details of any audits that have
been conducted on the company's
transfer pricing practices

Why Is It Requested?
This provides insight into any potential issues or risks with the company's trans-
fer pricing practices

How to Help Client Get It?

This provides insight into any potential issues or risks with the company's trans-
fer pricing practices

Transfer Pricing Information Request Checklist (v 2.0)

08
Industry
Reports
Reports that provide information
on the industry in which the
company operates

Why Is It Requested?
To understand the industry context in which the company operates

How to Help Client Get It?

These can often be obtained from the client, if not - search the Internet / use
ChatGPT with search enabled

Transfer Pricing Information Request Checklist (v 2.0)

09
Previous
Year(s) TP
Documentation
Transfer pricing documents from
previous years

Why Is It Requested?
To understand the company's historical transfer pricing practices; use them as a
starting point for the following years.

How to Help Client Get It?

These should be available from the client's tax or transfer pricing manager.

Transfer Pricing Information Request Checklist (v 2.0)

10
Annual Financial
Statement(s) of
the Company
The company's yearly financial
statements

Why Is It Requested?
These provide insight into the legal entity’s financial performance

How to Help Client Get It?

These should be readily available from the client's finance or accounting
department

Transfer Pricing Information Request Checklist (v 2.0)

11
Annual Financial
Statement(s) of
the Counterparty
The yearly financial statements of
the related party involved in the
intercompany transactions

Why Is It Requested?
The yearly financial statements of the related party involved in the intercompa-
ny transactions

How to Help Client Get It?

The client may need to request these from the related party

Transfer Pricing Information Request Checklist (v 2.0)

12
Information
about Internal
Comparable
Transactions
Information on similar
transactions within the company

Why Is It Requested?
To help determine if internal comparables are available and if internal CUP/re-
sale price/cost+ can be used.

How to Help Client Get It?

To help determine if internal comparables are available and if internal CUP/re-
sale price/cost+ can be used.

Transfer Pricing Information Request Checklist (v 2.0)

13
Segmented
Transactional
P&Ls
Profit and loss statements for
specific segments or transactions

Why Is It Requested?
To understand the profitability of specific business segments or transactions

How to Help Client Get It?

Help the client to generate these reports from their financial or ERP systems

Transfer Pricing Information Request Checklist (v 2.0)

14
Organizational
Charts
Diagrams that show the structure
of the organization

Why Is It Requested?
To understand the company's structure and how company is managed.

How to Help Client Get It?

Request these from the client's human resources or management teams

Transfer Pricing Information Request Checklist (v 2.0)

15
Ownership
Structure
Details on who owns the company
and its various subsidiaries

Why Is It Requested?
To understand the relationship between different entities in the corporate group

How to Help Client Get It?

This information should be available from theclient's legal or corporate gover-
nance department

Transfer Pricing Information Request Checklist (v 2.0)

16
Any
Advanced Pricing
Agreements (APAs)
Agreements between a taxpayer & a
tax authority on an appropriate
transfer pricing methodology

Why Is It Requested?
To understand any pre-agreed transfer pricing methods

How to Help Client Get It?

These should be available from the client's tax department

Transfer Pricing Information Request Checklist (v 2.0)

17
Other
Relevant
Documents
Any other documents that could be
relevant to the company's transfer
pricing practices

Why Is It Requested?
These can provide additional context or insight into the company's transfer pric-
ing practices

How to Help Client Get It?

This would depend on the specific document. Work with the client to identify
and gather any other potentially relevant documents

Transfer Pricing Information Request Checklist (v 2.0)

18
 Download
this checklist
here:

Credits to
Borys
Ulanenko

Follow on
LinkedIn!

Transfer Pricing Information Request Checklist (v 2.0)

19