Transfer Pricing Documentation Expert

Prepare audit-ready transfer pricing documentation packages compliant with OECD Guidelines and DACH/EU requirements. Covers master file, local file, functional analysis, benchmarking studies, and intercompany agreement structuring.

Gold

v1.0.00 activationsLegal & ComplianceLegalexpert

SupaScore

Research Quality (15%)

8.6

Prompt Engineering (25%)

8.4

Practical Utility (15%)

8.3

Completeness (10%)

8.5

User Satisfaction (20%)

8.2

Decision Usefulness (15%)

8.5

Best for

▸Preparing master file and local file documentation for OECD BEPS compliance
▸Conducting functional analysis for intercompany service agreements and IP licensing
▸Benchmarking studies for cost-plus manufacturing and distribution arrangements
▸Structuring intercompany loan agreements with arm's length pricing
▸Defending transfer pricing positions during German GAufzV or Austrian tax audits

What you'll get

●Comprehensive master file with organizational structure diagrams, business descriptions, and controlled transactions summary per OECD template
●Local file documentation with detailed controlled transactions analysis, financial information, and transfer pricing method justification
●Functional analysis report mapping value-creating activities, risk ownership, and asset usage with DEMPE framework application for IP transactions

Not designed for ↓

×General corporate tax planning or VAT compliance outside transfer pricing
×US transfer pricing documentation (focuses on OECD/EU/DACH requirements)
×Customs valuation or trade compliance matters
×Financial accounting for intercompany transactions (focuses on tax compliance)

Expects

Detailed information about the multinational group structure, specific intercompany transactions, functional roles of entities, and the relevant jurisdictions for documentation requirements.

Returns

Comprehensive transfer pricing documentation packages including master file/local file templates, functional analysis reports, benchmarking studies with economic analysis, and compliant intercompany agreements.

Evidence Policy

Enabled: this skill cites sources and distinguishes evidence from opinion.

transfer-pricingoecd-guidelinestax-compliancebenchmarkingfunctional-analysisarm-length-principlemaster-filelocal-filebepsintercompany-transactionsdach-taxdocumentation

Research Foundation: 8 sources (5 official docs, 1 industry frameworks, 2 books)

This skill was developed through independent research and synthesis. SupaSkills is not affiliated with or endorsed by any cited author or organisation.

Version History

v1.0.02/16/2026

Initial release

Works well with

Compliance Program ArchitectGold Financial Model BuilderPlatinum International Tax Planning AdvisorPlatinum Legal Document DrafterPlatinum Tax Strategy AdvisorGold

Need more depth?

Specialist skills that go deeper in areas this skill touches.

Transfer Pricing SpecialistGold International Tax Planning AdvisorPlatinum

Common Workflows

Multinational Tax Compliance Setup

Complete transfer pricing documentation followed by broader international tax planning and ongoing compliance program design for multinational operations

transfer-pricing-documentation-expert→International Tax Planning Advisor→Compliance Program Architect

Activate this skill in Claude Code

Start Free to Activate This Skill