TAX & COMPLIANCE

Transfer Pricing Documentation & Risk Management

Related-party transactions documented and priced defensibly, before a tax authority asks the question, not after.

ScopeDocumentation · Benchmarking · Risk review
Best forGroups with related-party transactions
CoveragePakistan & cross-border

Overview

Businesses with related-party transactions, between group companies, with a parent or subsidiary, or with connected persons, carry a specific and often underestimated exposure: tax authorities can, and do, challenge whether those transactions are priced at arm’s length. LeapWise prepares transfer pricing documentation, conducts benchmarking analysis, and manages the broader transfer pricing risk profile for businesses operating within a group structure or with cross-border related-party dealings.

The objective is straightforward: documentation and pricing that can be defended if challenged, prepared proactively rather than assembled under pressure once a query has already been raised.

Who Needs This Service

  • Group companies with intercompany transactions in goods, services, or financing
  • Businesses with a foreign parent, subsidiary or related entity
  • Companies facing a transfer pricing query or audit from a tax authority
  • Groups restructuring intercompany arrangements or pricing policies
  • Businesses expanding cross-border and establishing new related-party dealings
  • Organisations that have never formally documented their transfer pricing position

Our Approach

01

Transaction Mapping

All related-party transactions across the group are identified and categorised by type and materiality.

02

Benchmarking

Comparable, arm’s-length pricing benchmarks are researched and applied to test current intercompany pricing.

03

Documentation

Formal transfer pricing documentation is prepared, supporting the pricing policy with evidence and methodology.

04

Risk Review & Advisory

Ongoing exposure is assessed, and pricing policies are advised on before new intercompany arrangements are put in place.

Key Benefits

  • Documented, defensible positions ahead of any tax authority query
  • Reduced risk of transfer pricing adjustments and associated penalties
  • Clarity on which intercompany transactions carry the highest exposure
  • Pricing policies advised on before arrangements are finalised, not after
  • A documented methodology that can be updated as the group evolves
  • Stronger position in any transfer pricing audit or dispute

Frequently Asked Questions

Do we need transfer pricing documentation even if our group is relatively small?

Materiality and specific thresholds vary by situation. We assess your group’s related-party transactions and advise on the documentation position appropriate to your circumstances.

What counts as a related-party transaction?

This typically includes transactions with parent companies, subsidiaries, common directors or shareholders, and other connected persons, we map this specifically to your group structure.

We’re already facing a query from a tax authority, can you help now?

Yes, we can step in to prepare or strengthen documentation in response to an existing query, though earlier, proactive documentation is always the stronger position.

How often should transfer pricing documentation be updated?

It should be reviewed whenever intercompany arrangements change materially, and refreshed periodically to reflect current benchmarking data.

Ready to talk about transfer Pricing Documentation & Risk Management?

Reach out for a direct conversation about your business, no obligation, no generic sales pitch.