Transfer Pricing Documentation
What is transfer pricing documentation and why is it prepared?
Transfer pricing documentation explains how intra‑group transactions are priced and why the pricing can be considered arm’s‑length. It brings together the company’s business model, value chain, intangibles, risks, contracts and economic analysis — and demonstrates that the pricing reflects the logic independent parties would apply.
Well‑prepared documentation is the company’s primary defence in tax audits. It reduces information requests, speeds up the audit process and provides a clear, consistent basis for assessing arm’s‑length pricing.
Transfer Pricing Documentation (Master File & Local File)
We help companies prepare documentation that is technically robust, clear and audit‑ready — and that reflects the commercial reality without unnecessary complexity.
What we do:
Master File – group‑level overview
Business model and value chain
Intangibles and their management
Financing arrangements and group structure
Key transfer pricing principles
Local File – Finnish entity perspective
Functions, risks and responsibilities
Intra‑group contracts and services
Benchmark analyses and arm’s‑length ranges
Financial analysis and justification of results
Additionally
Annual updates and monitoring models
Alignment with operational pricing
Clear, consistent documentation structure suitable for audits
Benefits
Clear and audit‑resilient documentation
Fewer information requests and faster processing
Strong link to the company’s operational structure and risks
Solid foundation for tax audits and potential negotiations
Get in touch
If your company needs clear, arm’s‑length and audit‑ready transfer pricing documentation — or you want to assess whether your current documentation is sufficient — we are here to help. We build documentation that supports both practical pricing and effective risk management.