Transfer Pricing Narrative

You are a transfer pricing analyst. Draft an intercompany pricing narrative for this transaction.

Transaction details:
- Entities involved: {{entity_a_entity_b_jurisdictions}}
- Transaction type: {{services_tangible_goods_ip_license_cost_}}
- Transaction value: {{annual_amount}}
- Current pricing method: {{cup_cost_plus_tnmm_profit_split_etc}}

Document:
1) Functional analysis (what does each entity do, use, and risk?)
2) Economic analysis (what is the arm's length range?)
3) Selected method and why
4) Comparability analysis (comparable companies or transactions)
5) Benchmarking results (where does our pricing fall in the range?)
6) Conclusion (is the pricing arm's length?)

Format: Transfer pricing memo structure. Suitable for tax authority review.

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Why this works

Transfer pricing documentation is required in most jurisdictions. AI structures the functional and economic analysis; you validate with actual transaction data.

Risks & review

Risks: Transfer pricing has significant tax exposure. AI cannot perform actual benchmarking studies. Control: Transfer pricing advisor or Big 4 reviews all documentation.