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Question Checklist

1

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

2

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

3

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

4

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?

5

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?

6

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