Local File – What You Receive as Part of Our Transfer Pricing Documentation Service
We prepare a complete and compliant Local File in accordance with the OECD Transfer Pricing Guidelines.
Our goal is to ensure full tax compliance and protection in case of audits, while clearly presenting the commercial rationale and arm’s-length nature of your controlled transactions.
Scope of the Local File Documentation
Below is the full package delivered as part of our service.
1. Description of the Group and the Related Parties
We provide a comprehensive presentation of all related entities participating in controlled transactions, including:
management structure and organizational charts,
core business activities of each related party,
geographical markets in which entities operate,
industry landscape and competitive environment, relevant regulatory context,
group or entity economic strategy,SME status (if applicable),
material transfers of functions, assets, or risks, capital, managerial, and organizational links between related entities.
Outcome: transparent alignment of transactions with your statutory financial statements.
2. Description of Transactions
For each type of transaction, we include:
subject and nature of the transaction,
full functional analysis (functions, risks, and assets) for both parties,detailed description of activities performed,
assessment of risk assumption and risk-bearing capacity,
assets used in the provision of services,
transfer pricing method and pricing assumptions,transaction value by counterparty,
information on payments and settlements, including set-offs,intra-group agreements,
benchmarking analysis (transfer pricing analysis),
mapping of the transaction to the financial statements.
Outcome: a complete and compliant file demonstrating arm’s-length conditions for service transactions.
3. Annexes and Supporting Materials
We attach all supporting documents necessary for a complete Local File: organizational charts, intra-group agreements,benchmarking results, financial extracts used in TPR reporting (where relevant), supplementary evidence confirming the arm’s-length nature of transactions. Outcome: a complete, audit-ready documentation package.
What the Client Gains
✔ Full compliance with OECD Transfer Pricing Regulations All mandatory elements are included and prepared in a regulator-friendly format.
✔ Enhanced protection in case of a tax audit Documentation clearly defends the arm’s-length nature of pricing.
✔ Professional functional and benchmarking analyses We provide commercially realistic justification for applied transfer pricing.
✔ Clear mapping of transactions to financial statements A frequent point of scrutiny during audits is addressed explicitly.
✔ A structured, understandable, ready-to-use deliverable The documentation is designed to be practically helpful—not just formally compliant.
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