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
- Maintain a transaction inventory by nature (goods, services, intangibles, financing).
- Update functional analysis when the business model changes.
- Select methods with working papers that a reviewer can follow.
- 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