Global transfer pricing documentation and compliance

Transfer pricing documentation is increasingly a global compliance process rather than a local filing task. We help groups centrally manage master files, local files, transfer pricing forms, (Public) Country-by-Country Reporting support and related documentation requirements in a coordinated and scalable way.

Why this matters

Many groups struggle with fragmented documentation, inconsistent transaction descriptions, outdated benchmarks and local files that do not fully align with the master file or financial data. In Belgium and abroad, documentation should be complete, consistent and ready to support the transfer pricing positions taken and potentially disclosed in transfer pricing forms. Across jurisdictions, inconsistencies can quickly become audit triggers.

How we help

• Scope the documentation requirement: identify entities, transactions, materiality thresholds, local filing obligations and internal data owners.
• Coordinate master file and local file content: ensure that global value chain descriptions, transaction-level analysis and local financial data are consistent.
• Support Belgian TP forms: assist with Belgian master file, local file and CbC-related form requirements, including data consistency checks.
• Manage timelines and workflow: create documentation calendars, request lists, review gates and status reporting across jurisdictions.
• Refresh economic support: assess whether existing benchmarks remain usable and identify where refreshes or new analyses are required.
• Prepare audit-ready files: organise documentation, supporting evidence and data trails in a format that can be used efficiently if questions arise.

Typical deliverables

• Master file and local files
• Global coordination and review or localisation
• TP form support and consistency checks
• (Public) CbCR and CbC notification support
• Global documentation project plan and status dashboard
• Benchmark refresh schedule and compliance calendar
• Audit-readiness and preparation of supporting evidence

Typical triggers

• Belgian fiscal year-end documentation cycle
• First year within Belgian TP documentation thresholds
• Centrally coordinated global transfer pricing documentation needs involving multiple jurisdictions
• New entities or new intercompany transactions
• Inconsistent prior-year files or outdated benchmarks
• Upcoming tax audit or request for documentation