Conducting A Transfer Pricing Trial

It emphasizes that transfer pricing practitioners must go beyond merely preparing a transfer pricing study, local file, or master file. They must also ensure that all supporting documentation, such as surveys and interviews, is accessible and available. The taxpayer should leverage their intimate knowledge of the facts, as the tax authority relies on the information provided by them. It’s crucial to ensure that these facts are accurate and consistently presented in a manner that strengthens the taxpayer’s case.