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    Local File Checklist

    Uploaded by

    Borys Ulanenko
    This document is a checklist to help simplify preparing transfer pricing documentation by ensuring all necessary elements are included. It contains sections to review the presentation, format, and accuracy of the local file. It also provides a comprehensive list of all crucial points that must be addressed in the local file content, such as transaction overviews, functional analysis, comparability analysis, and compliance with OECD requirements. The goal is to make preparing the local file less overwhelming and more efficient.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Local File Checklist

    Uploaded by

    Borys Ulanenko
    96 views6 pages
    This document is a checklist to help simplify preparing transfer pricing documentation by ensuring all necessary elements are included. It contains sections to review the presentation, format, and accuracy of the local file. It also provides a comprehensive list of all crucial points that must be addressed in the local file content, such as transaction overviews, functional analysis, comparability analysis, and compliance with OECD requirements. The goal is to make preparing the local file less overwhelming and more efficient.

    Original Title

    Local File Checklist (6)

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    This document is a checklist to help simplify preparing transfer pricing documentation by ensuring all necessary elements are included. It contains sections to review the presentation, format, and accuracy of the local file. It also provides a comprehensive list of all crucial points that must be addressed in the local file content, such as transaction overviews, functional analysis, comparability analysis, and compliance with OECD requirements. The goal is to make preparing the local file less overwhelming and more efficient.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    96 views6 pages

    Local File Checklist

    Uploaded by

    Borys Ulanenko
    This document is a checklist to help simplify preparing transfer pricing documentation by ensuring all necessary elements are included. It contains sections to review the presentation, format, and accuracy of the local file. It also provides a comprehensive list of all crucial points that must be addressed in the local file content, such as transaction overviews, functional analysis, comparability analysis, and compliance with OECD requirements. The goal is to make preparing the local file less overwhelming and more efficient.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 6

    Local File

    Checklist
    Transfer Pricing Local
    File Checklist

    Welcome to the Local File Checklist, your comprehensive


    tool designed to simplify the complex task of preparing
    transfer pricing documentation.

    This tool is created to make your task of preparing or


    reviewing local file less overwhelming and more efficient,
    ensuring your documentation meets both content and
    presentation standards.

    Local File Checklist | 2


    This section focuses on refining the presentation and accuracy aspects of your local file. It helps
    ensuing proper formatting of all elements of the document, such as abbreviations, table of contents,
    graph labeling, and citation formats.

    Formatting Review
    Abbreviation
    Explanation Yes No
    Consistency
    Abbreviation
    Ensure abbreviations are used consistently throughout the document
    Consistency

    Table of Contents Confirm that the table of contents is up-to-date with correct page numbers

    Graphs Labelling Verify all graphs, charts, and diagrams are labeled and referenced in the text

    Confirm all tables have correct numbering, titles, and are accurately
    Table Labelling
    referenced in the text

    No Tables Broke Ensure figures and tables do not break across pages unless absolutely necessary

    Citation Check Check for proper citation formatting for all referenced sources

    Footnote Format Verify all necessary footnotes are present and correctly formatted

    Confirm financial figures follow a consistent format (e.g., currency signs, use
    Number Formatting
    of commas/periods)

    Hyperlinks Verification Ensure all hyperlinks or URLs are functioning and direct to the correct webpage

    Confirm headings and subheadings are correctly and consistently used to


    Heading Consistency
    separate different sections

    Margin Compliance Check the document follows the correct margin guidelines

    Alignment Consistency Ensure text alignment is consistent throughout the document

    Spacing Uniformity Check line spacing is uniform across the document

    Blank Spaces Confirm there are no blank pages or unnecessary spacing between sections

    Font Uniformity Ensure consistent usage of typefaces and font sizes throughout the document

    Color Scheme Check the document follows the color scheme, if applicable, for better
    Adherence legibility

    Language Accuracy Verify spellings, grammar, and punctuation are correct and consistent

    Appendix Reference Confirm appendices are labeled and referenced appropriately within the document

    Legal References Check legislation and OECD references are correct and up-to-date

    Confirm financial figures (such as transactional values, PLIs, etc.) are in line
    Numbers Accuracy
    with source files

    Local File Checklist | 3


    This section provides a comprehensive list that covers every crucial point your local file should address.
    From articulating your legal entity business to ensuring consistent alignment with other reporting forms,
    this section provides a detailed guide to make your local file content-rich and fully compliant.

    Content Review
    Review Criteria Description Yes No

    Transactional Detailed account and figures of the controlled transactions during the year,
    Overview with explanation of their substance, is provided

    Identification and substantiation of the functions, risks, and assets of the


    Functional Analysis
    local entity and its counterparties

    Intercompany List of the intercompany agreements affecting transactions and explanation


    Agreements of their implementation is provided

    Transfer Pricing Description of the local entity's transfer pricing policy relevant for controlled
    Policy transactions and the company's pricing practices is provided

    Transfer Pricing Selected OECD/local transfer pricing method(s) are stated and their
    Method appropriacy is justified, with explanation on why others aren't applied

    Comparability Explanation of the process of comparability analysis, the relevance of the


    Analysis selected comparables, the database choice, and filters applied is provided

    Reliability and alignment of financial data used for transfer pricing analyses
    Financial Information with the entity's financial accounts is confirmed, with demonstration of its
    tie to the P&L/balance sheet

    Description and justification of any pricing adjustments made, with


    Pricing Adjustment
    explanation of their reflection in financial accounts, is provided

    Arm's Length Verification of whether the controlled transactions outcome aligns with the
    Confirmation arm's length principle and justification of belief is provided

    Country-Specific
    Compliance of the local file with any specific country rules is confirmed
    Rules

    Counterparty Local Comparison of this local file with the counterparty’s file and explanation of
    File any differences is provided

    Assurance that the local file presents a clear and convincing story that
    Story
    arrangements are at arm's length

    Consistency Assurance that the local file aligns with TP forms, CbCR, and master file

    Local File Checklist | 4


    OECD Local File Requirements

    Management structure and business strategy, highlighting recent significant changes.

    List of key competitors.

    Brief overview of controlled transactions.

    Summary of intra-group payments/receipts per transaction type and tax jurisdiction.

    List of associated enterprises in transactions.

    Copies of material intercompany agreements.

    Summary of comparability and functional analysis, noting year-to-year changes.

    Identified transfer pricing method with justification.

    Identification of tested party and reasoning.

    Summary of key assumptions in methodology.

    Justification for multi-year analysis, if relevant.

    Overview of comparable transactions and related financial indicators.

    Summary of comparability adjustments made.

    Justification for arm’s length pricing of transactions.

    Summary of financial data used in methodology.

    Copies of relevant APAs and other tax rulings.

    Annual financial accounts of the local entity.

    Schedules linking financial data with annual financial statements.

    Summary schedules of financial data for comparables.

    Local File Checklist | 5


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