There are several steps to an effective transfer pricing study, as detailed below:
This should be a straightforward exercise to ensure a full understanding of what documentation currently exists and what types of product, intangibles or services are involved, the key issues to consider are described in B4.171.
This simply involves gathering information via information requests and interviews. It is important to obtain an industry analysis, which establishes the competitive landscape for the intercompany transactions.
This is the process of determining the economically relevant facts and characteristics in the intercompany transactions and is necessary before a research strategy is established and analysis is undertaken. This is not a restatement of the facts or summary of the facts. The functional analysis should follow on naturally from fact gathering, examination of company operations and industry analysis. It should analyse the economically significant characteristics (not all aspects of company operations) as well as provide a perspective for statement
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