# Draft Transfer Pricing Documentation > A transfer pricing documentation review memorandum must assess a multinational documentation package against the applicable transfer pricing documentation framework, analyze entity substance and DEMPE functions, identify local compliance deadlines as urgent action items, and produce both a risk quantification table and an action item matrix. - Skill: `finchipaiorg/draft-transfer-pricing-documentation` (Agent Skill) - Install (CLI): `npx skillmds@latest add finchipaiorg/draft-transfer-pricing-documentation` - Raw SKILL.md: https://api.skillmd.com/api/skills/finchipaiorg/draft-transfer-pricing-documentation/raw - Safety review: pending - Works with: Claude Code, Claude.ai, OpenAI Codex - Category: Docs & Writing - Author: FinchipAIOrg (https://skillmd.com/u/finchipaiorg) - Updated: 2026-09-22 - Page: https://skillmd.com/skills/finchipaiorg/draft-transfer-pricing-documentation --- # Skill: Draft Transfer Pricing Documentation Review Memorandum ## 1. Subject-matter triage - Determine first whether the package contains a group overview, jurisdictional local files, and any country-by-country element that is relevant to the group. - Identify all jurisdictions, entities, intercompany agreements, benchmarking reports, valuation materials, treasury papers, and filing instructions before analyzing adequacy. - If only one entity, one jurisdiction, or one transaction type is actually in scope, state that expressly and analyze it as such; do not imply broader coverage. ## 2. Failure modes the skill is correcting - Identifying documentation gaps without separating critical compliance defects from items that can be remediated on a normal cycle. - Missing local-file language, certification, or filing requirements where a jurisdiction imposes them, including deadlines tied to the return cycle. - Reviewing agreements without testing the pricing terms, amortization periods, and valuation support against each other for consistency. - Describing risk without assigning an ordinal severity, a quantified exposure band, and a downstream consequence. - Producing a narrative review without a risk table, compliance calendar, and action matrix. - Failing to convert identified issues into concrete remedial steps with a responsible role and timing anchor. ## 3. Legal frameworks / domain conventions that apply - Apply the relevant transfer pricing documentation framework for the group, including a group-level file, local files by jurisdiction, and any country-by-country reporting component where applicable. - Evaluate intangible ownership and residual return allocation through the DEMPE lens: development, enhancement, maintenance, protection, and exploitation must be mapped to actual personnel, decision-making authority, and control of risk. - Test intercompany pricing against arm’s-length principles under the applicable transfer pricing regime and the benchmarking study used in the package. - Check local filing, language, and certification requirements under the relevant domestic transfer pricing rules and tax-return calendar for each jurisdiction. - For cost sharing, buy-in, or other pre-existing intangible valuation support, reconcile the legal and accounting amortization treatment to the valuation methodology and stated useful life. - For royalty arrangements, assess the comparables set, whether non-comparable licenses distort the range, and whether the applied rate remains defensible after filtering. - For treasury structures, evaluate spread adequacy and capitalization sufficiency together; thin capitalization can undermine both deduction support and return adequacy. ## 4. Analytical scaffolds 1. **Document inventory and completeness check** - List each document type, entity, and jurisdiction. - Identify missing, stale, inconsistent, or unsigned materials. - Note any language, certification, or filing defects. 2. **Entity-by-entity substance and DEMPE review** - Identify the functions performed by each relevant entity. - Test whether personnel, control, and risk-bearing align with the claimed return. - State whether the residual IP return allocation is defensible and why. 3. **Intercompany agreement consistency review** - Compare contractual pricing, term, amortization, and payment mechanics against operational records and supporting studies. - Flag inconsistencies between stated terms and observed practice. - Cross-reference related agreements or schedules that affect the same transaction. 4. **Jurisdictional local-file review** - For each jurisdiction, confirm language, format, sign-off, and deadline requirements. - Distinguish imminent filings from later-cycle items. - Treat pending audits or information requests as background pressure only; they do not extend statutory deadlines. 5. **Valuation and royalty support review** - Test buy-in or similar valuation support for consistency with the contractual treatment. - Assess the royalty benchmark set, comparable selection, and range sensitivity to questionable comparables. - State the consequence if the applied rate falls outside or near the edge of the range. 6. **Treasury and financing review** - Evaluate spread between funding cost and lending rate. - Assess capitalization and funding structure together. - Identify whether the structure creates pricing, deduction, or substance concerns. 7. **Issue-level closure discipline** - For each issue, include: severity, quantified scale or threshold, cross-reference to the interacting document or clause, and downstream consequence. - Avoid standalone observations that do not end in a conclusion and remedial path. 8. **Risk quantification table** - Include every issue in a table with severity and exposure band. - Use consistent bands such as low, medium, and high, with a short rationale for each. 9. **Action item matrix** - Translate each issue into one or more actions. - Assign a responsible role and a timing anchor. - Make urgent filing items explicit and separate from broader cleanup work. ## 5. Vertical / structural / temporal relationships - Track relationships between master file statements and local-file positions so that group-level descriptions do not conflict with country-specific facts. - Track relationships between agreement terms and implementation records, especially pricing, amortization, payment timing, and invoicing. - Track relationships between valuation assumptions and accounting treatment, particularly useful life, method, and start date. - Track relationships between filing deadlines, return due dates, and any local language or certification requirements. - Where multiple jurisdictions are involved, enumerate them explicitly and analyze each one separately rather than collapsing them into a single regional assessment. ## 6. Output structure conventions - Begin with a short executive summary stating overall documentation quality, principal risks, and the most urgent remediation items. - Follow with issue-by-issue findings, each using a uniform severity label such as Critical, High, Medium, or Low. - For each issue, state the document or provision implicated, the governing transfer pricing principle or domestic compliance rule, the quantified exposure or scale, and the practical consequence. - Include a separate risk quantification table with all issues and their exposure bands. - Include a separate compliance calendar for imminent local-file, certification, and return-linked deadlines. - Include a separate action matrix with issue, priority, responsible role, and deadline. - End with a Recommended Actions section that uses imperative verbs and specifies who must do what by when. - Use conventional memorandum formatting; do not imitate a rubric checklist or expose hidden scoring categories.