Transfer Pricing Documentation
Transfer pricing documentation that survives an audit.
Master File, Local Files, and Country-by-Country Reporting, built to OECD BEPS Action 13 standards. Delivered in about four weeks, refreshed every year, and contemporaneous when the auditor asks.
Trusted by global businesses
The PDF from three years ago
is not protection.
Tax authorities in the US, UK, EU, India, and Australia have all expanded their transfer pricing audit programs in the last three years. When the questionnaire arrives, the only thing standing between your intercompany pricing and an adjustment is the documentation file.
Stale documentation is barely better than none
Most companies got their documentation done two or three years ago with a Big Four firm and haven't touched it since. New entities, new transaction types, new jurisdictions: the policy that covered the business then almost certainly doesn't cover it now.
Penalties are a percentage, not a flat fine
Transfer pricing penalties in most jurisdictions are calculated as a percentage of the adjustment. The IRS can impose penalties of 20-40% of the underpayment. Contemporaneous documentation is what takes those penalties off the table.
Every jurisdiction wants its own file
A US-centric package doesn't satisfy the local file rules in India, Germany, or Australia. Each jurisdiction sets its own content requirements, thresholds, and deadlines, and each one audits independently.
What you get
What the service includes.
Master File
The group-level document: structure, value chain, intangibles, financing, and global transfer pricing policy, structured to OECD BEPS Action 13 standards.
Local Files, per jurisdiction
Entity-level analysis written against each country's specific content requirements, not one template stamped across your footprint.
Country-by-Country Reporting
CbCR prepared and filed where required, with notifications tracked and submitted in every jurisdiction that expects one.
Functional analysis and benchmarking
Functions, assets, and risks attributed per entity, and every arm's length position supported by a database-driven comparables search.
Annual refresh, included
Local File updates trigger automatically at year-end. Annual updates are part of the engagement, not a $15-40K invoice you weigh every year.
Penalty protection by design
Version-controlled, contemporaneous documentation in place before filing deadlines, so a pricing dispute stays a pricing dispute instead of a penalty case.
How it works
Audit-ready in weeks,
not months.
A defined workflow with milestone-based delivery: from kickoff to a complete draft package in about four weeks.
Step 01
Map the transactions
We map every intercompany transaction across all related parties, confirm which files each jurisdiction requires, and fix the scope upfront.
Step 02
Analyze and benchmark
Functional analysis attributes functions, assets, and risks per entity. Benchmarking establishes the arm's length range for each transaction type.
Step 03
Draft and review
Master File, Local Files, and CbCR drafted to OECD Action 13 standards. You review the package before anything is finalized or filed.
Step 04
Maintain, every year
Annual updates trigger at year-end, filing deadlines are tracked per jurisdiction, and every version is recorded. The package never goes stale.
A project,
or a system.
Advisors deliver the same documents at advisory rates, then quote again next year. Commenda systematizes the recurring work, so the package is produced once and maintained continuously.
Big Four / boutique TP advisory
A documentation project, every time.
- 4-6 months to first deliverable
- $30-80K initial engagement cost
- $15-40K per annual update, quoted separately
- Documentation in a PDF. Not a system.
- Updates happen when you remember to commission them
- Deep jurisdiction expertise (retain for complex one-offs)
Commenda documentation
A documentation system, maintained.
- Complete draft package in ~4 weeks
- Defined scope, fixed cost, milestone-based delivery
- Annual updates included in the engagement
- Version-controlled: every update tracked
- Filing deadlines tracked per jurisdiction
- TP experts behind every deliverable
Where it fits
Documentation is the output.
The agreements come first.
A documentation package is only as strong as the benchmarking and the intercompany agreements underneath it. Commenda covers the full lifecycle on one platform: agreements, benchmarking, documentation, and filing.
Common questions
It depends on where your entities sit and how big the group is. The Master File covers the group: structure, value chain, and global policy. Local Files are jurisdiction-specific and carry the entity-level analysis; most countries with TP rules expect one once you cross local thresholds. Country-by-Country Reporting applies only to large groups above a consolidated revenue threshold, so most mid-market companies don't need it yet. We map your entities and transactions first, then tell you exactly which files each jurisdiction requires.
Contemporaneous means the documentation exists when you file the return, not assembled after an auditor asks. The distinction matters because in most jurisdictions, contemporaneous documentation is what protects you from transfer pricing penalties: with it, a pricing adjustment is a tax bill; without it, the adjustment comes with penalties calculated as a percentage of the underpayment. The IRS can impose penalties of 20-40% of the underpayment. Commenda's annual cycle keeps the package current before deadlines, so the protection is always in place.
Yes, and this is a common starting point. We review the existing package, keep what still reflects the business, and rebuild what doesn't: new entities, new transaction types, changed functional profiles. From there the documentation moves onto an annual refresh cycle instead of waiting for the next $15-40K one-off update.
About four weeks from kickoff to a complete draft package, compared to the 4-6 months a typical Big Four engagement runs. The timeline holds because the work is systematized: transaction mapping, functional analysis, benchmarking, and drafting run as a defined workflow with milestone-based delivery, not an open-ended advisory project.
Yes. Every arm's length position in the package is supported by a database-driven comparables search with an interquartile range and documented methodology. Documentation that cites stale or unsupported ranges is the first thing an auditor attacks, so the benchmarking is part of the engagement, not a separate line item you discover later.
The documentation gets updated, and that's included. Annual Local File updates are triggered at year-end, and material changes during the year, like a new entity or a new transaction type, are folded into the next refresh. Every version is tracked, so you can always show an auditor what the documentation said at any point in time.
Get documentation an
auditor can't dismiss.
Book a 30-minute call. We'll review your intercompany structure, tell you exactly which files each jurisdiction requires, and show you what the finished package looks like.
