Topic resources
Transfer Pricing Documentation and Auditor Certification
Browse the guidance and official references below for Transfer Pricing Documentation and Auditor Certification. The linked articles explain their coverage and any conditions that need checking for your case.
Working checklist
Use this working checklist with the accompanying guide. Fill in the actual period, authority, due date and evidence; a blank checklist does not establish compliance.
Download the editable checklist (CSV)
| Check | Record before closing |
|---|---|
| Covered taxpayer, transaction and income year | Applicable period, source, owner, due date and evidence |
| Related parties and ownership links | Applicable period, source, owner, due date and evidence |
| Controlled-transaction register | Applicable period, source, owner, due date and evidence |
| Contracts and actual conduct | Applicable period, source, owner, due date and evidence |
| Functional, asset and risk analysis | Applicable period, source, owner, due date and evidence |
| Method selection and reasons | Applicable period, source, owner, due date and evidence |
| Comparable search and source date | Applicable period, source, owner, due date and evidence |
| Adjustments and financial reconciliation | Applicable period, source, owner, due date and evidence |
| Arm’s-length conclusion and computation | Applicable period, source, owner, due date and evidence |
| Applicable annual reporting / disclosure | Applicable period, source, owner, due date and evidence |
| Safe-harbour eligibility if relied upon | Applicable period, source, owner, due date and evidence |
| APA scope and validity if present | Applicable period, source, owner, due date and evidence |
| Current directive and Finance Act overlay | Applicable period, source, owner, due date and evidence |
| Auditor certification requirement and evidence | Applicable period, source, owner, due date and evidence |
| Review owner and unresolved items | Applicable period, source, owner, due date and evidence |
Official references
Check the source and period
Confirm the income year, treaty status and effective date before applying cross-border rules.
Keep the relevant Act, rules, annual amendments and authority notices together. The layout update date is not a new legal review date.
Latest update
- 13 October 2026
Editor: C.M. & Associates
Reviewed the resource directory, its article mapping and source-period guidance. Clarified source labels and public wording where needed. Earlier source-check dates and any stated limitations remain applicable.