Transfer Pricing Specialist
Analyze intercompany transactions, select appropriate transfer pricing methods, design OECD-compliant documentation strategies, and navigate BEPS requirements for multinational enterprises.
SupaScore
84.4Best for
- ▸Selecting appropriate transfer pricing methods (CUP, TNMM, Profit Split) for specific intercompany transactions
- ▸Preparing three-tier documentation (Master File, Local File, CbCR) for OECD compliance
- ▸DEMPE analysis for intangible asset transfer pricing including development, enhancement, maintenance, protection, and exploitation
- ▸Advance Pricing Agreement strategy development and negotiation preparation
- ▸BEPS Action 8-10 compliance for profit attribution and value creation alignment
What you'll get
- ●Detailed functional analysis with risk allocation framework, tested party selection rationale, and TNMM application with comparable company benchmarking study
- ●DEMPE analysis report documenting development functions, legal ownership, and economic substance with profit attribution recommendations
- ●Three-tier documentation package including Master File organizational structure, Local File transaction details, and Country-by-Country reporting templates
Not designed for ↓
- ×General tax planning or domestic tax compliance outside transfer pricing
- ×Financial accounting treatment of intercompany transactions
- ×Legal entity structuring or corporate formation advice
- ×Customs valuation or trade duty optimization
Detailed description of multinational enterprise structure, specific intercompany transactions, functional analysis data, and target jurisdictions for transfer pricing analysis.
Comprehensive transfer pricing documentation including method selection rationale, benchmarking analysis, risk assessment, and OECD-compliant supporting documentation.
Risk Domain: finance. This skill covers financial topics. Verify outputs with a qualified professional.
Evidence Policy
Enabled: this skill cites sources and distinguishes evidence from opinion.
Research Foundation: 8 sources (4 official docs, 1 industry frameworks, 1 expert knowledge, 2 academic)
This skill was developed through independent research and synthesis. SupaSkills is not affiliated with or endorsed by any cited author or organisation.
Version History
Initial release
Prerequisites
Use these skills first for best results.
Works well with
Need more depth?
Specialist skills that go deeper in areas this skill touches.
Common Workflows
Transfer Pricing Documentation Compliance
Complete transfer pricing analysis, documentation preparation, and ongoing regulatory monitoring for multinational compliance
Activate this skill in Claude Code
Sign up for free to access the full system prompt via REST API or MCP.
Start Free to Activate This Skill© 2026 Kill The Dragon GmbH. This skill and its system prompt are protected by copyright. Unauthorised redistribution is prohibited. Terms of Service · Legal Notice