Transfer pricing year-end documentation checklist 2026

For each controlled transaction#

1. Delineate the transaction

   The parties, what was supplied, the contractual terms and how the parties actually behaved — conduct can matter more than the contract.

2. Record functions, assets and risks

   Who performs each function, owns each asset and controls and bears each risk, with the evidence that shows it.

3. Choose the method, with the reason

   The method and why it suits this transaction; the tested party and why.

4. Tie it to the accounts

   The amounts in the documentation agree to the ledger for the period.

5. Check agreements are signed

   An unsigned intercompany agreement is a draft and should be recorded as one.

The local file, in outline#

• The local entity: management structure, business and strategy.
• Each material controlled transaction, its amounts, counterparties and agreements.
• The comparability and functional analysis, and the method selected.
• The financial information the analysis rests on.

What TaxOrch does and does not do here#

TaxOrch keeps the inventory of controlled transactions, the functional analysis and the method with its reasons, and lets documentation rest only on approved transactions. Benchmarking studies with external comparables are prepared separately and linked to the file.

What this rests on

1. 1OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2022) — Chapter I (accurate delineation) and Chapter V, Annex II (local file)OECDin force from 20 January 2022

Locators, not document titles. A citation naming the act without naming the section is not one anybody can check.

Where this fits

• Research and citationsWhere cross-border tax and treaties is covered in depth

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