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Keeping transfer pricing documentation audit-ready

Contemporaneous documentation is easier than reconstructing a year’s related-party story under notice timelines.

Who typically needs a Form 3CEB conversation

Groups with international related-party transactions above prescribed thresholds, or complex domestic specified domestic transactions, should map obligations early in the year — not in September.

What “contemporaneous” looks like in practice

  1. Maintain a transaction inventory by nature (goods, services, intangibles, financing).
  2. Update functional analysis when the business model changes.
  3. Select methods with working papers that a reviewer can follow.
  4. Archive agreements, invoices and board notes that support the pricing policy.

A simple calendar

  • Q1: Confirm entity map and threshold monitoring
  • Q2–Q3: Refresh benchmarking where required
  • Pre year-end: Align intercompany invoices to policy
  • Post year-end: Local file + accountant’s report coordination

Talk to international tax