Essential Skills and Knowledge for a Transfer Pricing Professional

As a transfer pricing practitioner, navigating the complex landscape of international taxation and multinational enterprise (MNE) operations requires a unique blend of technical expertise, analytical skills, and strategic insight. Transfer pricing, which involves setting prices for transactions between related entities within an MNE, is a critical area of tax compliance and planning due to its impact on tax bases across jurisdictions. This article explores the essential skills and knowledge areas that are vital for excelling as a transfer pricing practitioner, ensuring compliance with global standards like the OECD Transfer Pricing Guidelines, and effectively managing the challenges posed by cross-border transactions. With the increasing scrutiny from tax authorities worldwide and the evolving nature of international tax rules, such as those stemming from the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative, the role of a transfer pricing professional has never been more pivotal. As a transfer pricing practitioner, navigating the complex landscape of international taxation and multinational enterprise (MNE) operations requires a unique blend of technical expertise, analytical skills, and strategic insight. Transfer pricing, which involves setting prices for transactions between related entities within an MNE, is a critical area of tax compliance and planning due to its impact on tax bases across jurisdictions. This article explores the essential skills and knowledge areas that are vital for excelling as a transfer pricing practitioner, ensuring compliance with global standards like the OECD Transfer Pricing Guidelines, and effectively managing the challenges posed by cross-border transactions. With the increasing scrutiny from tax authorities worldwide and the evolving nature of international tax rules, such as those stemming from the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative, the role of a transfer pricing professional has never been more pivotal.

Technical Knowledge of Transfer Pricing Frameworks

A foundational requirement for any transfer pricing practitioner is a deep understanding of the international frameworks that govern transfer pricing, particularly the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. These guidelines, updated periodically with significant revisions in 2015 and beyond as part of the BEPS project, provide the bedrock for applying the arm’s length principle, which is the cornerstone of transfer pricing ¹. The arm’s length principle mandates that transactions between related parties should be priced as if they were conducted between independent entities under comparable circumstances. Mastery of this principle, as articulated in Article 9 of the UN and OECD Model Tax Conventions, is non-negotiable for ensuring compliance and defending pricing policies during audits ².

Beyond the arm’s length principle, practitioners must be well-versed in the various transfer pricing methods outlined in the OECD Guidelines, including traditional transaction methods like the Comparable Uncontrolled Price (CUP) method, Resale Price method, and Cost Plus method, as well as transactional profit methods such as the Transactional Net Margin Method (TNMM) and Profit Split method ³. Each method has specific applications depending on the nature of the transaction and the availability of comparable data, and a skilled practitioner must know how to select and apply the most appropriate method to the circumstances of the case. Additionally, understanding the nuances of special considerations for intangibles, intra-group services, and cost contribution arrangements, as detailed in Chapters VI, VII, and VIII of the OECD Guidelines, is crucial given the increasing importance of these areas in modern MNE operations ⁴.

Knowledge of domestic transfer pricing regulations in multiple jurisdictions is equally important, as rules can vary significantly despite the overarching influence of OECD standards. For instance, the U.S. Transfer Pricing Regulations under Section 482 of the Internal Revenue Code provide detailed guidance on acceptable pricing methods and documentation, which may differ in application from other countries’ approaches. Practitioners must also stay updated on evolving international tax standards, such as the BEPS Action 13 requirements for Country-by-Country (CbC) reporting, which mandate detailed documentation to enhance transparency ⁵. This technical knowledge ensures that practitioners can design compliant transfer pricing policies and mitigate risks of double taxation or penalties.

Analytical and Research Skills for Comparability Analysis

One of the most critical skills for a transfer pricing practitioner is the ability to conduct a thorough comparability analysis, a process central to applying the arm’s length principle ⁶. As outlined in Chapter III of the OECD Guidelines, comparability analysis involves comparing controlled transactions (between related entities) with uncontrolled transactions (between independent entities) to determine whether the pricing aligns with market standards. This requires strong analytical skills to evaluate factors such as the characteristics of the property or services transferred, the functions performed, assets used, risks assumed by each party, contractual terms, economic circumstances, and business strategies ⁷.

Practitioners must be adept at sourcing and interpreting data from commercial databases to identify comparable transactions or companies, a task often complicated by the lack of reliable data, especially in developing countries ⁸. The UN Practical Manual on Transfer Pricing highlights the challenge of finding comparables in less developed markets where organized operators are scarce, and data may be incomplete or inaccessible. Therefore, research skills are paramount to navigate these limitations, including the ability to make reasoned adjustments to account for differences between controlled and uncontrolled transactions ⁹. Proficiency in statistical analysis to establish an arm’s length range or central point within that range further enhances a practitioner’s ability to defend pricing decisions during tax audits.

Moreover, analytical skills extend to understanding the economic context of transactions. For instance, transfer pricing practitioners must assess location-specific advantages or disadvantages, such as cost savings from operating in certain jurisdictions, and incorporate these into their analyses ¹⁰. This requires not only number-crunching ability but also a strategic mindset to interpret how economic and market conditions influence pricing outcomes.

Economic and Financial Acumen

A robust understanding of economics and finance is indispensable for transfer pricing practitioners, as transfer pricing is fundamentally about valuing transactions in a way that reflects economic reality ¹¹. Knowledge of economic principles helps in assessing the profit potential of transactions and the allocation of income and expenses within an MNE group, as discussed in the OECD Guidelines. For example, when applying the Profit Split method, practitioners must evaluate the relative contributions of each entity to the combined profit, often relying on economic indicators and market data to support their conclusions ¹².

Financial acumen is equally critical, particularly in analyzing financial statements to determine appropriate profit margins or cost structures under methods like TNMM or Cost Plus. Practitioners must be comfortable with concepts such as gross margins, operating profits, and return on assets, as these metrics often form the basis of transfer pricing calculations. Additionally, understanding the financial implications of business restructurings, as covered in Chapter IX of the OECD Guidelines, is vital, especially when assessing the reallocation of profit potential or the transfer of valuable assets ¹³.

The ability to model financial outcomes under different transfer pricing scenarios is a valuable skill, enabling practitioners to advise MNEs on optimizing their tax positions while remaining compliant. This includes understanding the impact of tax rate differentials across jurisdictions, which can incentivize profit shifting if not managed within the bounds of the arm’s length principle. A solid grasp of financial instruments and transactions, as addressed in recent updates to the OECD Guidelines (Chapter X), is also necessary given the growing complexity of intra-group financing arrangements ¹⁴.

Legal and Regulatory Awareness

Transfer pricing is deeply intertwined with legal and regulatory frameworks, making legal awareness a key competency for practitioners ¹⁵. Familiarity with international tax treaties, particularly the UN and OECD Model Tax Conventions, is essential for understanding how transfer pricing disputes are resolved through mechanisms like the Mutual Agreement Procedure (MAP) under Article 25. Practitioners must also be aware of domestic tax laws and how they interact with international guidelines, as discrepancies can lead to disputes or double taxation ¹⁶.

Knowledge of dispute resolution mechanisms, such as Advance Pricing Arrangements (APAs) and arbitration, as detailed in Chapter IV of the OECD Guidelines, equips practitioners to proactively manage risks ¹⁷. APAs, for instance, allow taxpayers to agree on transfer pricing methodologies with tax authorities in advance, reducing uncertainty over a fixed period. Understanding the legal nuances of corresponding adjustments—where one jurisdiction adjusts a taxpayer’s profits, and another must make a corresponding adjustment to avoid double taxation—is critical for navigating cross-border issues ¹⁸.

Additionally, practitioners should be conversant with documentation requirements, such as the three-tiered approach (Master File, Local File, and CbC Report) introduced by BEPS Action 13, to ensure compliance and transparency ¹⁹. Legal awareness extends to recognizing the implications of penalties for non-compliance or fraud, as noted in the UN Model Tax Convention, where adjustments may not be mirrored if willful default is involved ²⁰. This knowledge helps practitioners advise clients on maintaining robust documentation and defending against aggressive tax authority challenges.

Communication and Negotiation Skills

Effective communication is a cornerstone of success in transfer pricing, given the need to interact with diverse stakeholders, including tax authorities, MNE management, and legal counsel ²¹. Practitioners must be able to clearly articulate complex transfer pricing concepts and methodologies to non-specialists, ensuring that internal teams understand compliance requirements and strategic implications. This skill is particularly important when preparing transfer pricing documentation or presenting analyses during audits, where clarity can influence outcomes.

Negotiation skills are equally vital, especially in the context of APAs or MAP discussions with tax authorities ²². The OECD Guidelines emphasize the importance of cooperative approaches in resolving disputes, and practitioners must be adept at negotiating mutually satisfactory solutions that balance taxpayer interests with regulatory compliance. For instance, when dealing with multiple jurisdictions, a practitioner may need to mediate between conflicting tax authority positions to prevent double taxation, requiring tact and persuasive communication ²³.

Moreover, transfer pricing often involves internal negotiations within MNEs to align transfer pricing policies with business objectives. Communication skills are crucial in affecting earnings, as found in research exploring the impact of local workers’ communication skills on the transfer of soft and hard skills. Practitioners must communicate the tax implications of different pricing strategies to business units, ensuring that operational decisions do not inadvertently create compliance risks. The ability to build consensus among stakeholders with differing priorities—such as finance teams focused on cost minimization and tax teams focused on compliance—is a critical soft skill. Soft skills include critical thinking, teamwork, leadership, written and oral communication, and the ability to research independently.

Strategic Thinking and Problem-Solving

Transfer pricing is not merely a compliance exercise; it is a strategic tool for MNEs to manage their global tax positions. Practitioners must possess strategic thinking skills to design transfer pricing policies that align with an MNE’s broader business goals while adhering to the arm’s length principle. This involves anticipating how changes in business models, such as digitalization or restructuring, might impact transfer pricing, and proactively adjusting policies to mitigate risks.

Problem-solving skills are essential when addressing complex issues like the valuation of intangibles, a growing challenge in the digital economy as noted in the UN Manual ²⁴. Intangibles are often unique and lack direct comparables, requiring creative approaches to valuation that withstand scrutiny from tax authorities. Practitioners must also navigate scenarios where data is scarce, particularly in developing countries, by leveraging alternative methods or making reasoned assumptions supported by robust documentation.

Strategic foresight is also necessary to stay ahead of regulatory changes. The BEPS initiative and the OECD/G20 Inclusive Framework have introduced significant updates to transfer pricing rules, and practitioners must anticipate how these changes will affect their clients’ operations. For example, understanding the implications of standardized CbC reporting can help MNEs prepare for increased transparency demands from tax authorities. This forward-thinking approach ensures that transfer pricing strategies remain sustainable in a dynamic global tax environment ²⁵.

Cultural and Ethical Awareness

Given the international scope of transfer pricing, cultural awareness is a valuable skill for practitioners working with diverse teams and tax authorities across jurisdictions. Cross-cultural understanding is essential for transfer pricing experts to navigate different tax systems, cultural nuances, and regulatory frameworks. Understanding cultural nuances in communication and negotiation can facilitate smoother interactions and dispute resolutions, particularly in mutual agreement procedures involving multiple countries. For instance, approaches to compliance and enforcement may differ between developed and developing countries, and sensitivity to these differences can enhance collaboration ²⁶.

Ethical awareness is equally important, as transfer pricing practitioners often face pressure to minimize tax liabilities for MNEs while adhering to legal and regulatory standards ²⁷. The OECD Guidelines encourage taxpayers to apply the arm’s length principle in good faith, and practitioners must resist temptations to engage in aggressive tax planning that could be perceived as profit shifting or tax avoidance. Upholding ethical standards not only protects the practitioner’s reputation but also builds trust with tax authorities, reducing the likelihood of contentious audits ²⁸.

Technological Proficiency

In the era of digital transformation, technological proficiency is becoming a critical skill for transfer pricing practitioners. The increasing reliance on data analytics for comparability studies and the automation of documentation processes necessitate familiarity with specialized software and databases used in transfer pricing analysis. Tools for financial modeling and statistical analysis can enhance the accuracy of pricing calculations, while technology for managing CbC reporting requirements streamlines compliance efforts.

Moreover, the rise of the digital economy poses unique transfer pricing challenges, such as valuing data-driven intangibles or assessing the tax implications of remote operations. Practitioners must be comfortable with emerging technologies and their impact on business models to provide relevant advice. Staying abreast of technological advancements ensures that transfer pricing strategies remain aligned with modern economic realities.

Data Analytics and Artificial Intelligence

The integration of data analytics and artificial intelligence (AI) is revolutionizing transfer pricing practices, making these skills increasingly valuable for practitioners. Advanced analytics can process vast amounts of transaction data to identify patterns, anomalies, and potential risks, enabling more informed decision-making. For instance, predictive analytics can forecast the impact of different pricing strategies on tax liabilities across jurisdictions, while prescriptive analytics can suggest optimal pricing approaches based on historical data and regulatory requirements.

AI applications in transfer pricing include automated benchmarking, intelligent document processing, and risk assessment algorithms. These technologies can significantly reduce the time spent on routine tasks, allowing practitioners to focus on higher-value activities such as strategic planning and dispute resolution. For example, natural language processing (NLP) can analyze tax authority rulings and guidelines to identify emerging trends and potential audit risks, while machine learning algorithms can enhance the accuracy of comparability analyses by identifying subtle patterns in financial data.

Proficiency in using data analytics platforms and understanding the principles of AI applications enables practitioners to leverage these technologies effectively in their practice. As tax authorities increasingly adopt data-driven approaches to audit selection and enforcement, practitioners with these skills will be better positioned to anticipate challenges and develop robust responses ²⁹.

Industry-Specific Expertise

Developing expertise in specific industries can significantly enhance a transfer pricing practitioner’s effectiveness and marketability. Different industries have unique value chains, business models, and profit drivers that influence transfer pricing approaches. For example, the pharmaceutical industry faces distinct challenges related to R&D costs, intellectual property valuation, and regulatory considerations, while the digital economy grapples with issues such as data valuation and the allocation of profits from online platforms.

Industry knowledge enables practitioners to identify relevant comparables more accurately, select appropriate transfer pricing methods, and develop defensible valuation approaches for industry-specific intangibles. It also facilitates more effective communication with clients by demonstrating an understanding of their business context and operational challenges. Furthermore, industry expertise allows practitioners to anticipate sector-specific regulatory developments and tailor their advice accordingly.

To develop industry expertise, practitioners should stay informed about industry trends, participate in sector-focused conferences and forums, and build relationships with industry professionals. This specialized knowledge, combined with transfer pricing technical skills, positions practitioners as valuable advisors who can provide insights beyond mere compliance considerations.

Project Management Skills

Effective project management is essential for transfer pricing practitioners who often handle multiple complex engagements simultaneously with tight deadlines. Transfer pricing projects, such as preparing documentation for multiple entities across different jurisdictions or conducting comprehensive economic analyses, require careful planning, resource allocation, and timeline management. Strong project management skills enable practitioners to deliver high-quality work efficiently, enhancing client satisfaction and firm profitability.

Key project management competencies include the ability to scope projects accurately, develop realistic timelines, coordinate cross-functional teams, and manage client expectations. Practitioners should also be adept at identifying potential bottlenecks, such as data availability challenges or resource constraints, and developing contingency plans to address them. Moreover, the ability to adapt project plans in response to changing circumstances, such as evolving client needs or unexpected regulatory developments, is crucial in the dynamic field of transfer pricing.

Project management tools and methodologies, such as Gantt charts, project management software, and agile approaches, can enhance practitioners’ effectiveness in coordinating complex transfer pricing engagements. Developing these skills not only improves operational efficiency but also demonstrates professionalism and reliability to clients and colleagues.

Risk Management Abilities

Transfer pricing involves significant risks for MNEs, including potential double taxation, penalties for non-compliance, reputational damage, and business disruption due to protracted disputes. Effective risk management is therefore a crucial skill for transfer pricing practitioners, enabling them to identify, assess, and mitigate these risks proactively. This involves understanding not only technical tax risks but also broader business and operational risks that may arise from transfer pricing decisions.

Key risk management competencies include the ability to conduct comprehensive risk assessments, develop risk mitigation strategies, and implement robust governance frameworks for transfer pricing ³⁰. Practitioners should be skilled in assessing the likelihood and potential impact of various risks, such as transfer pricing adjustments, penalties, or adverse court decisions, and prioritizing risk management efforts accordingly. They should also be able to communicate risk insights effectively to stakeholders, enabling informed decision-making at all levels of the organization.

Client Relationship Management

For transfer pricing practitioners in advisory roles, strong client relationship management skills are essential for building long-term partnerships and delivering exceptional service. This involves understanding clients’ business objectives, industry context, and risk appetite, and tailoring transfer pricing advice accordingly. Effective client relationship management also requires proactive communication, responsiveness to client needs, and the ability to translate complex technical concepts into actionable insights for decision-makers.

Key competencies in this area include active listening to understand client concerns, empathy to appreciate their challenges, and the ability to build trust through consistent delivery of high-quality work ³¹. Practitioners should also be skilled in managing client expectations by clearly communicating project scopes, timelines, and potential challenges, and providing regular updates on progress and emerging issues ³².

Furthermore, practitioners should be adept at identifying opportunities to add value beyond the immediate engagement, such as alerting clients to relevant regulatory developments or suggesting process improvements for transfer pricing compliance. This consultative approach strengthens client relationships and positions the practitioner as a trusted advisor rather than merely a technical specialist.

Continuous Learning and Professional Development

The field of transfer pricing is constantly evolving due to regulatory changes, technological advancements, and shifts in global business practices ³³. Successful practitioners must therefore cultivate a mindset of continuous learning and commit to ongoing professional development. This involves staying updated on changes to transfer pricing guidelines, emerging best practices, and new analytical techniques, as well as developing complementary skills in areas such as data analytics, project management, and industry-specific knowledge.

Effective approaches to continuous learning include participating in professional education programs, attending industry conferences and webinars, joining professional associations, engaging in peer discussions, and reading relevant publications. Many jurisdictions also require tax professionals to complete continuing professional education (CPE) credits to maintain certifications, making formal learning a regulatory requirement as well as a professional advantage.

Beyond formal education, experiential learning through diverse project experiences, mentorship relationships, and cross-functional collaborations can significantly enhance a practitioner’s capabilities. Reflective practice, in which practitioners critically evaluate their performance and identify areas for improvement, is also valuable for continuous growth.

Documentation Excellence

High-quality documentation is a cornerstone of effective transfer pricing practice, serving both compliance and strategic objectives ³⁴. Transfer pricing documentation not only demonstrates compliance with regulatory requirements but also provides a basis for defending pricing policies during tax audits and serves as a reference for implementing consistent approaches across an organization. Practitioners must therefore excel in creating comprehensive, clear, and defensible documentation that meets both legal requirements and practical business needs.

Key documentation skills include the ability to organize complex information logically, communicate technical analyses clearly, and tailor documentation to different audiences and purposes. Practitioners should be adept at preparing different types of documentation, such as master files, local files, country-by-country reports, and transfer pricing policies, each with its specific focus and requirements.

Furthermore, practitioners should understand the strategic role of documentation in risk management, using it not only to demonstrate compliance but also to identify potential vulnerabilities and develop mitigation strategies. This includes maintaining contemporaneous documentation that captures the rationale for pricing decisions at the time they are made, which can be crucial in defending against subsequent challenges ³⁵.

Conclusion

Becoming a proficient transfer pricing practitioner demands a multifaceted skill set that spans technical expertise, analytical prowess, economic and financial understanding, legal awareness, and strategic acumen. The ability to communicate effectively, negotiate with stakeholders, and navigate cultural and ethical considerations further enhances a practitioner’s effectiveness in this field. As global tax landscapes continue to evolve with initiatives like BEPS and the digital economy’s expansion, technological proficiency, data analytics capabilities, and adaptability are increasingly vital.

Beyond these foundational skills, emerging competencies such as data analytics and AI proficiency, industry-specific expertise, project management, risk management, client relationship management, continuous learning, and documentation excellence are becoming increasingly important for transfer pricing professionals. By cultivating these skills and knowledge areas, transfer pricing practitioners can not only ensure compliance with international standards but also add strategic value to MNEs, protecting tax bases and fostering cross-border trade.

This comprehensive expertise positions practitioners to tackle the complexities of transfer pricing with confidence and integrity, making them indispensable in the realm of international taxation. As the field continues to evolve, successful practitioners will be those who commit to lifelong learning, embrace technological innovations, and maintain a balanced perspective that considers both technical accuracy and practical business realities.

1. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter I, paragraph 1.1.
2. OECD, Model Tax Convention on Income and on Capital, 2017, Article 9.
3. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter II, paragraphs 2.1-2.12.
4. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapters VI-VIII.
5. OECD/G20 Base Erosion and Profit Shifting Project, Transfer Pricing Documentation and Country-by-Country Reporting, Action 13: 2015 Final Report, OECD Publishing, Paris.
6. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter III, paragraphs 3.1-3.5.
7. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter III, paragraphs 3.38-3.117.
8. United Nations Practical Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter B.2, paragraph B.2.3.4.
9. United Nations Practical Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter B.2, paragraphs B.2.3.5-B.2.3.6.
10. IBFD, “Location Benefits in Transfer Pricing,” 2024, International Bureau of Fiscal Documentation.
11. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter I, paragraphs 1.33-1.63.
12. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter II, paragraphs 2.114-2.151.
13. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter IX.
14. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter X.
15. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter IV, paragraphs 4.1-4.19.
16. United Nations Model Double Taxation Convention between Developed and Developing Countries, 2017, United Nations, New York, Article 25.
17. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter IV, paragraphs 4.134-4.174.
18. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter IV, paragraphs 4.29-4.31.
19. OECD/G20 Base Erosion and Profit Shifting Project, Transfer Pricing Documentation and Country-by-Country Reporting, Action 13: 2015 Final Report, OECD Publishing, Paris, Chapter V.
20. United Nations Model Double Taxation Convention between Developed and Developing Countries, 2017, United Nations, New York, Article 9, paragraph 2.
21. The preparation of transfer pricing documentation requires developing soft skills such as building good teamwork, establishing good communication with clients, thinking critically and more logically, Ecojoin.org, 2022.
22. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter IV, paragraphs 4.1-4.19.
23. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter IV, paragraphs 4.29-4.31.
24. United Nations Practical Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter B.5.
25. OECD/G20 Base Erosion and Profit Shifting Project, Transfer Pricing Documentation and Country-by-Country Reporting, Action 13: 2015 Final Report, OECD Publishing, Paris.
26. United Nations Practical Manual on Transfer Pricing for Developing Countries, 2021, United Nations, New York, Chapter C.1.
27. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Preface, paragraphs 15-17.
28. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, OECD Publishing, Paris, Chapter IV, paragraphs 4.1-4.19.
29. “An Approach to BEPS Risk Assessment: Applying Data Analytics Techniques to Country-by-Country Reporting Data”, IBFD, 2022.
30. HMRC identifies “Governance Risks” as one of three categories of transfer pricing risks, along with “Design Risks” and “Execution Risks”, DLA Piper, 2024.
31. “Especially for participants aged 70 to 84 years, a relationship of trust is important” in professional relationships, MDPI.com, 2022.
32. “CRM Strategies For Financial Advisors In Tax Planning”, Stephanie Dannebaum, 2024.
33. “Continuous Learning: A Key Component of Effective Tax Strategy”, EOXS, 2025.
34. “Quality transfer pricing documentation will: (i) ensure that taxpayers give appropriate consideration to transfer pricing requirements in establishing prices for transactions between associated enterprises; (ii) provide tax administrations with the information necessary to conduct an informed transfer pricing risk assessment; and (iii) provide tax administrations with useful information to use in evaluating a taxpayer’s transfer pricing positions upon audit”, UN Practical Manual on Transfer Pricing, Chapter C.2.
35. “Countries have different timing requirements for the production of transfer pricing documentation. Any requirement that requires preparation of documentation at the time of the transaction, at the time the tax return is filed, or at the beginning of an audit may be referred to as a ‘contemporaneous’ documentation requirement”, UN Practical Manual on Transfer Pricing, Chapter C.2.4.2.1.