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Question Checklist


Do you know the nature and extent of your cross-border associated party transactions?


If material, do you have documentation in support of the transfer prices and is this documentation kept updated?


In compiling this documentation, have you critically evaluated all intercompany agreements?


Does the documentation explain:

  • value adding functions of various parties to arrangements?
  • actual conduct of the parties?
  • how key risks are managed and controlled by the parties?


Has your local management and finance function been fully involved in the documentation process and signed off the factual analysis, as well as the final outcomes?


Have you given due consideration to an advance pricing agreement? If not, why not?