Transfer Pricing Documenter

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name: transfer-pricing-documenter
description: Documents an intercompany transaction for transfer pricing purposes — functional analysis (functions, assets, risks), method selection reasoned from that analysis, and a benchmarking record built only from comparables actually supplied — flagging jurisdiction-specific documentation thresholds and method hierarchy rules for verification. Use this whenever a user needs a related-party transaction documented or benchmarked — including phrasings like "document this intercompany service arrangement for transfer pricing", "which method fits this royalty arrangement", "build the FAR analysis for this distribution structure", or "check whether this margin falls within an arm's length range on these comparables". Jurisdiction-neutral — never assumes a specific transfer pricing regime applies. Fires for any related-party or intercompany transaction requiring transfer pricing documentation, in any jurisdiction.
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# Transfer Pricing Documenter

## What this does

Documents an intercompany transaction for transfer pricing purposes: a functional analysis of what each party does, owns, and risks; a transfer pricing method selected and reasoned from that analysis; and a benchmarking record testing the actual result against comparables. It organises the analysis and documents it in the form a transfer pricing file requires; it does not itself source external comparable-company data, and it does not assume a specific jurisdiction's method hierarchy, threshold, or safe harbour without that being confirmed.

## Before you start

**The intercompany transaction facts.** The related parties and their relationship, the nature of the transaction — sale of goods, services, royalty, financing, or another category — and the pricing or terms actually used.

**The governing transfer pricing framework and jurisdiction.** Ask; do not assume OECD Guidelines apply wholesale or that any specific jurisdiction's rules govern without confirming. Documentation requirements, method hierarchy, and safe harbours are law-specific even where the underlying structure is similar across regimes.

Not blocking, ask once and proceed on what is supplied: **whether comparable or benchmarking data is already available**, or needs to be sourced separately. This skill documents and organises the analysis; it works from comparables the user supplies or that are sourced this session, not from invented benchmarks.

## Method

**1. Confirm the related-party relationship and why it triggers transfer pricing rules** — the ownership or control basis for treating the parties as related. State it precisely as given; do not assume a specific ownership percentage threshold applies without flagging that the threshold is jurisdiction-specific.

**2. Conduct the functional analysis** — the functions performed, the assets employed (including intangibles), and the risks assumed by each party to the transaction — based only on the facts supplied, flagging any gap where the functional profile is not yet clear rather than filling it with an assumption.

**3. Characterise each party's role based on the functional analysis** — for instance, a limited-risk distributor against a full-fledged manufacturer — as a description that follows from the facts given, not as a conclusion asserted without that support.

**4. Select the transfer pricing method that best fits the transaction and the functional profile**, and explain why. Do not assert a specific jurisdiction's documented method hierarchy or preference from memory; flag it for verification if the choice depends on one.

**5. Document the benchmarking analysis using only comparables the user has supplied or that were sourced this session.** Do not invent a comparable company or a benchmark range to complete the analysis.

**6. State the tested party and the profit level indicator used**, tied to the method selected in step 4.

**7. Compare the actual result against the benchmark range** and state whether it falls within an arm's length range on the facts and comparables actually given — not on an assumed or typical range.

**8. Flag documentation and filing requirements as jurisdiction- and value-specific**, requiring verification rather than assumption — whether a formal transfer pricing study, local file, or master file is required depends on both the governing law and the transaction value.

**9. Note any safe harbour or simplified-documentation provision only if sourced or supplied**; otherwise flag its potential availability as a verification point rather than asserting it applies.

## Output

**1. Header.** Related parties and their relationship, transaction type, governing framework and jurisdiction, period, date.

**2. Functional analysis.** A table of functions, assets, and risks by party.

**3. Characterisation.** Each party's role, tied to the functional analysis.

**4. Method selection.** The method chosen, with reasoning tied to the functional profile.

**5. Benchmarking analysis.** Comparables used (as supplied or sourced), tested party, profit level indicator, and the resulting range.

**6. Arm's length conclusion.** Whether the actual result falls within range, on the facts and comparables given.

**7. Documentation and filing requirements.** Flagged for jurisdiction- and value-specific verification.

**8. Points requiring verification.** Method hierarchy or preference rules, documentation thresholds, and safe harbour availability.

## Do not

Do not invent a comparable company or a benchmark range that was not supplied or sourced.

Do not assume a specific jurisdiction's method hierarchy or documentation threshold without flagging it for verification.

Do not assume an ownership or control threshold that triggers related-party status without confirming it is appropriate to the governing law.

Do not characterise a party's functional role beyond what the facts of the functional analysis actually support.

Do not assert that a specific safe harbour applies without it being sourced or supplied.