Transfer Pricing Policy (TP Policy) – OECD

A Transfer Pricing Policy is a strategic document that sets out the principles for intra-group settlements, pricing methods, margin determination, cost allocation rules and internal procedures ensuring compliance with tax regulations. It is applied globally in line with the OECD Guidelines and locally as a best-practice tool that reduces tax and operational risks.
A well-designed TP Policy ensures consistency across all group entities, alignment with Local File/Master File, coherent reporting in TPR and CbCR, and transparent internal processes.

As part of the service, we prepare:

‍1. Analysis of the group and existing settlement model: we begin by reviewing the group structure, controlled transactions and intra-group flows. This includes a FAR analysis, assessment of current pricing mechanisms, verification of alignment with Local File/Master File/TPR, and identification of business objectives relevant to the policy design.

‍2. Design of an OECD-compliant settlement model: we develop a complete pricing model for all categories of intra-group transactions, including services, financing, distribution, manufacturing, intangibles, shared costs and restructurings.
The model defines applicable TP methods, pricing logic, margin formulas, allocation keys and the economic justification required under OECD standards.

‍3. Development of internal governance and compliance procedures: we prepare practical procedures describing responsibilities, data collection, annual monitoring, year-end adjustments, documentation flows, communication rules and internal controls.
The aim is to establish a repeatable and compliant process for all entities in the group.

‍4. Preparation of the Transfer Pricing Policy document: we deliver a complete TP Policy that includes the group overview, transaction classification, applied methods, pricing rules, allocation mechanisms, adjustment procedures, and operational templates. The document is structured for easy implementation both locally and across the international group.

‍Client outcome: a TP Policy prepared by our team ensures compliance with OECD and local regulations, standardises intra-group pricing across the organisation, reduces audit risks, streamlines the preparation of TP documentation and reporting, strengthens internal governance, and increases transparency and tax certainty within the group.