---
name: transfer-pricing-documentation
description: "Use when documenting related-party transactions for transfer-pricing purposes: master file, local file, CbC reporting thresholds, and benchmarking evidence."
status: active
metadata:
portable: true
category: 08-tax-and-statutory
compatible_with:
- claude-code
- codex
Transfer Pricing Documentation
Use When
Use when a finance, accounting, reporting, controls, systems, or sector workflow needs country-specific statutory mechanics, fiscal-document controls, tax account mapping, and verified-current source-register use.
Do Not Use When
Do not use as a substitute for professional judgement, current statutory verification, full standard text, legal advice, actuarial valuation, tax opinion, or named reviewer approval where the engagement requires it.
Required Inputs
Entity profile, reporting framework, jurisdiction, functional currency, period, source events, source documents, account map, dimensions, source-register snapshot where statutory values appear, and reviewer route.
Workflow
Frame the accounting question, confirm the applicable framework, collect source evidence, apply the decision rules, create the ledger/reporting/control artefact, reconcile it to source records, and route exceptions or judgemental decisions to the named reviewer role.
Quality Standards
Framework-identified, source-evidenced, reviewer-routable, ledger-reconcilable, period-aware, and caveated where external law, standards, rates, or judgemental estimates remain pending.
Anti-Patterns
Using unsupported rates or facts, bypassing the posting service, releasing final statutory output without verified-current source-register entries, hiding judgement calls in free text, or treating illustrative examples as client facts.
Outputs
Decision memo, configured policy, posting/reporting map, reconciliation evidence, exception queue, reviewer routing record, and worked example.
References
Load references/source-basis.md, references/implementation-rules.md, and the canonical doctrine references before applying this skill.
Prerequisites
- Read doctrine/accounting-finance-doctrine.md.
- Read doctrine/references/policy-hierarchy.md.
- Read doctrine/references/ledger-invariants.md.
- Read references/source-basis.md.
- Read references/implementation-rules.md.
- Confirm framework, jurisdiction, functional currency, reporting period, entity type, and reviewer route.
Inputs
| Artifact |
Produced by |
Required? |
Validation |
| Scope and framework memo |
Engagement owner |
Required |
Names the entity, period, reporting framework, jurisdiction, and functional currency. |
| Source-event pack |
Subledger, integration, or preparer |
Required |
Source document, actor, date, period, amount, currency, account, dimension, and evidence pointer captured. |
| Policy and judgement log |
Controller or preparer |
Required for judgemental items |
Distinguishes standard requirement, management judgement, estimate, and inference. |
| Source-register snapshot |
Country-pack owner |
Required when statutory values appear |
Entries are verified-current or explicitly blocked from final output. |
| Reviewer route |
Doctrine owner |
Required |
Owner role and reviewer role are named before release. |
Outputs
| Artifact |
Consumed by |
Acceptance evidence |
| Decision memo |
Controller and reviewer |
States the question, framework, source basis, decision, caveat, and reviewer route. |
| Posting or reporting map |
GL, close, reporting, or integration owner |
Maps source event to account, dimension, period, currency, and evidence pointer. |
| Reconciliation workpaper |
Close owner and auditor |
Ties source records to subledger, control account, report line, and exception queue. |
| Exception register |
Controller and reviewer |
Captures blocked, missing, stale, disputed, or judgemental items with owner and due date. |
| Worked example |
Implementer and tester |
Reproducible example under examples/worked-example.md; no client facts implied. |
Decision Rules
- Identify the applicable reporting framework and scope boundary before recognition, measurement, disclosure, control, or workflow design.
- Treat the source document as the unit of evidence; every output must drill back to source document, actor, period, account, dimension, and audit log.
- If a posting is required, route it through the canonical posting service and enforce balance, period state, currency, idempotency, and reversal rules.
- If statutory, tax, payroll, exchange-rate, or fiscal-device values appear, use only verified-current source-register entries or block final release.
- Record judgemental decisions separately from facts, with reviewer role, evidence considered, rejected alternatives, and caveats.
- Reconcile operational records to the GL control account before reporting, settlement, close sign-off, or external disclosure.
- Maintain an exception register for missing evidence, stale source-register values, unsupported framework assumptions, unresolved estimates, and review blockers.
- Do not promote illustrative examples, assumed facts, or generic rates into client output.
Acceptance Evidence
- references/source-basis.md lists the official or canonical sources used for this skill and assigns source tiers.
- references/implementation-rules.md translates the source basis into local doctrine rules, blocked-output rules, and review gates.
- examples/worked-example.md shows a minimal evidence-backed artefact, posting/reporting impact, reconciliation, and reviewer route.
- The skill is active for doctrine use, but client-specific statutory/legal final output still requires current source-register verification and reviewer approval.
Anti-Patterns
- Treating draft client facts, example figures, or unsupported management assumptions as verified evidence.
- Posting directly to the ledger without the posting service or without an idempotency key.
- Releasing final statutory output from a stale, missing, or unverified source-register entry.
- Combining multiple judgement calls into a single unexplained adjustment.
- Omitting the exception register because the amount is small.
- Using this skill without loading its source basis and implementation rules.
Files
- references/source-basis.md
- references/implementation-rules.md
- examples/worked-example.md
Review Metadata
| Field |
Value |
| Owner role |
Doctrine owner |
| Reviewer roles |
Tax reviewer; country-pack owner; integration owner where fiscal devices are affected |
| Last reviewed |
2026-05-25 |
| Next review due |
2026-11-25 |
| Release state |
Active doctrine content; client-specific release remains subject to reviewer approval and verified-current statutory sources where applicable. |
| Caveat |
No human reviewer name has been fabricated. Record named reviewer sign-off in the engagement or release log when obtained. |
Last reviewed: 2026-05-25. Next review due: 2026-11-25.
1---2name: transfer-pricing-documentation3description: ---4---5---6name: transfer-pricing-documentation7description: "Use when documenting related-party transactions for transfer-pricing purposes: master file, local file, CbC reporting thresholds, and benchmarking evidence."8status: active9metadata:10 portable: true11 category: 08-tax-and-statutory12 compatible_with:13 - claude-code14 - codex15---1617# Transfer Pricing Documentation1819<!-- dual-compat-start -->20## Use When2122Use when a finance, accounting, reporting, controls, systems, or sector workflow needs country-specific statutory mechanics, fiscal-document controls, tax account mapping, and verified-current source-register use.2324## Do Not Use When2526Do not use as a substitute for professional judgement, current statutory verification, full standard text, legal advice, actuarial valuation, tax opinion, or named reviewer approval where the engagement requires it.2728## Required Inputs2930Entity profile, reporting framework, jurisdiction, functional currency, period, source events, source documents, account map, dimensions, source-register snapshot where statutory values appear, and reviewer route.3132## Workflow3334Frame the accounting question, confirm the applicable framework, collect source evidence, apply the decision rules, create the ledger/reporting/control artefact, reconcile it to source records, and route exceptions or judgemental decisions to the named reviewer role.3536## Quality Standards3738Framework-identified, source-evidenced, reviewer-routable, ledger-reconcilable, period-aware, and caveated where external law, standards, rates, or judgemental estimates remain pending.3940## Anti-Patterns4142Using unsupported rates or facts, bypassing the posting service, releasing final statutory output without verified-current source-register entries, hiding judgement calls in free text, or treating illustrative examples as client facts.4344## Outputs4546Decision memo, configured policy, posting/reporting map, reconciliation evidence, exception queue, reviewer routing record, and worked example.4748## References4950Load references/source-basis.md, references/implementation-rules.md, and the canonical doctrine references before applying this skill.51<!-- dual-compat-end -->5253## Prerequisites5455- Read doctrine/accounting-finance-doctrine.md.56- Read doctrine/references/policy-hierarchy.md.57- Read doctrine/references/ledger-invariants.md.58- Read references/source-basis.md.59- Read references/implementation-rules.md.60- Confirm framework, jurisdiction, functional currency, reporting period, entity type, and reviewer route.6162## Inputs6364| Artifact | Produced by | Required? | Validation |65|---|---|---|---|66| Scope and framework memo | Engagement owner | Required | Names the entity, period, reporting framework, jurisdiction, and functional currency. |67| Source-event pack | Subledger, integration, or preparer | Required | Source document, actor, date, period, amount, currency, account, dimension, and evidence pointer captured. |68| Policy and judgement log | Controller or preparer | Required for judgemental items | Distinguishes standard requirement, management judgement, estimate, and inference. |69| Source-register snapshot | Country-pack owner | Required when statutory values appear | Entries are verified-current or explicitly blocked from final output. |70| Reviewer route | Doctrine owner | Required | Owner role and reviewer role are named before release. |7172## Outputs7374| Artifact | Consumed by | Acceptance evidence |75|---|---|---|76| Decision memo | Controller and reviewer | States the question, framework, source basis, decision, caveat, and reviewer route. |77| Posting or reporting map | GL, close, reporting, or integration owner | Maps source event to account, dimension, period, currency, and evidence pointer. |78| Reconciliation workpaper | Close owner and auditor | Ties source records to subledger, control account, report line, and exception queue. |79| Exception register | Controller and reviewer | Captures blocked, missing, stale, disputed, or judgemental items with owner and due date. |80| Worked example | Implementer and tester | Reproducible example under examples/worked-example.md; no client facts implied. |8182## Decision Rules83841. Identify the applicable reporting framework and scope boundary before recognition, measurement, disclosure, control, or workflow design.852. Treat the source document as the unit of evidence; every output must drill back to source document, actor, period, account, dimension, and audit log.863. If a posting is required, route it through the canonical posting service and enforce balance, period state, currency, idempotency, and reversal rules.874. If statutory, tax, payroll, exchange-rate, or fiscal-device values appear, use only verified-current source-register entries or block final release.885. Record judgemental decisions separately from facts, with reviewer role, evidence considered, rejected alternatives, and caveats.896. Reconcile operational records to the GL control account before reporting, settlement, close sign-off, or external disclosure.907. Maintain an exception register for missing evidence, stale source-register values, unsupported framework assumptions, unresolved estimates, and review blockers.918. Do not promote illustrative examples, assumed facts, or generic rates into client output.9293## Acceptance Evidence9495- references/source-basis.md lists the official or canonical sources used for this skill and assigns source tiers.96- references/implementation-rules.md translates the source basis into local doctrine rules, blocked-output rules, and review gates.97- examples/worked-example.md shows a minimal evidence-backed artefact, posting/reporting impact, reconciliation, and reviewer route.98- The skill is active for doctrine use, but client-specific statutory/legal final output still requires current source-register verification and reviewer approval.99100## Anti-Patterns101102- Treating draft client facts, example figures, or unsupported management assumptions as verified evidence.103- Posting directly to the ledger without the posting service or without an idempotency key.104- Releasing final statutory output from a stale, missing, or unverified source-register entry.105- Combining multiple judgement calls into a single unexplained adjustment.106- Omitting the exception register because the amount is small.107- Using this skill without loading its source basis and implementation rules.108109## Files110111- references/source-basis.md112- references/implementation-rules.md113- examples/worked-example.md114115## Review Metadata116117| Field | Value |118|---|---|119| Owner role | Doctrine owner |120| Reviewer roles | Tax reviewer; country-pack owner; integration owner where fiscal devices are affected |121| Last reviewed | 2026-05-25 |122| Next review due | 2026-11-25 |123| Release state | Active doctrine content; client-specific release remains subject to reviewer approval and verified-current statutory sources where applicable. |124| Caveat | No human reviewer name has been fabricated. Record named reviewer sign-off in the engagement or release log when obtained. |125126Last reviewed: 2026-05-25. Next review due: 2026-11-25.
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