Failure to maintain adequate transfer pricing (TP) documentation can result in penalties and audit challenges, and in many cases companies cannot or do not prepare this documentation themselves. Global core documentation (GCD) and TP Elements allow us to help companies of all sizes, both by preparing your TP documentation and providing a framework that helps you understand the requirements so you can prepare it yourself.
We prepare TP documentation to demonstrate the arm’s length nature of your intercompany transactions meet the requirements in section 247 of the Income Tax Act. Services vary depending on your company’s needs: Global core documentation is an option for MNEs with more complex requirements, while smaller companies can take advantage of our TP Elements service, which offers several alternatives depending on needs and budget.
© 2018 - 2019 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.