Recent updates to transfer pricing documentation requirements raise the level of detail expected from groups with cross-border activity. The changes are administrative on paper, but operationally meaningful for entities preparing year-end documentation.
What’s new
- Lower thresholds for the comprehensive documentation requirement.
- Tighter timelines between the request and submission of the master file / local file.
- Greater focus on substance — economic rationale, not just formal compliance.
How NOA approaches it
Our transfer pricing team supports clients through risk assessment, benchmarking, documentation, and where necessary, defence in audits or disputes. Our work is grounded in fiscal substance, not template compliance.
