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Increased TP documentation requirements according to BEPS Action Item 13

As part of its BEPS project, the OECD has revised its guidance on TP documentation, suggesting a three-tiered structure consisting of a master file, local files and country-by-country reporting.
Extended TP documentation contents include the following:

  • Description of the supply chain
  • Important transactions related to intangibles, financial transactions and business restructurings
  • Provision of APAs/rulings agreements within the documentation package

Approaches to extended TP documentation requirements

  • Many multinationals enterprises (MNEs) differ in their documentation approach depending on size, complexity and structure of the MNE group.
  • Common approaches vary from group-wide, centrally prepared documentation to autonomous TP documentation by each local entity across the globe.
  • MNEs will need to review their TP documentation and processes to produce them in a consistent and cost-efficient way.

How can we help?

We have developed a comprehensive TP documentation tool that can help you streamline your internal processes and generate reporting packages that could support you in satisfying the TP documentation requirements under BEPS Action 13.


TP Web™

TP Web™ is an integrated IT platform for generating BEPS 13-related TP documentation. It flexibly adjusts to your requirements and supports you in undertaking ongoing assessment and monitoring. TP Web™ replaces the manual TP documentation process through automated procedures, providing for:

  • Cost and resource efficiency
  • High degree of consistency
  • Transfer pricing documentation that could support you in satisfying the TP document requirements under BEPS Action 13

  Watch our TP Web™ Introduction Video