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Transfer pricing documentation

Transfer pricing documentation is the file a company must hold to prove that the prices charged between entities of its group comply with the arm's length principle. It follows the two-tier structure recommended by the OECD in Action 13 of the BEPS project: a master file describing the group, and a local file describing the local entity's transactions.

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The master file covers the group as a whole. It sets out the legal and operating structure, the intangibles held, the intragroup financing arrangements, and the consolidated financial and tax position. One master file serves the entire group.

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The local file covers one entity and is where audits actually focus. A usable local file documents, for each material transaction:

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  • the nature and amount of the transaction, and the counterparty entity involved
  • the functions performed, assets used and risks assumed by each party
  • the transfer pricing method selected and why it fits the transaction
  • the comparables used, with the resulting arm's length range
  • the intragroup agreements governing the flow, and evidence the service was rendered

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In France, documentation is mandatory above thresholds that recent finance legislation lowered significantly, and the minimum penalty for failing to produce it was raised to 50,000 euros per audited financial year. A separate country-by-country report applies to groups above 750 million euros of consolidated revenue. Below the thresholds, prices must still be defensible: only the formal obligation differs.

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The recurring failure is evidentiary rather than technical. Reconstructing a cost base, an allocation key and proof of delivery three years after the fact is what makes an audit expensive. Phacet produces that trail continuously: the invoice versus contract control agent checks each intragroup invoice against the agreement, leaving an audit trail that supports audit-ready processes.

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