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transfer-pricing-documenter

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Documents an intercompany transaction for transfer pricing purposes — functional analysis (functions, assets, risks), method selection reasoned from that analysis, and a benchmarking record built only from comparables actually supplied — flagging jurisdiction-specific documentation thresholds and method hierarchy rules for verification. Use this whenever a user needs a related-party transaction documented or benchmarked — including phrasings like "document this intercompany service arrangement for transfer pricing", "which method fits this royalty arrangement", "build the FAR analysis for this distribution structure", or "check whether this margin falls within an arm's length range on these comparables". Jurisdiction-neutral — never assumes a specific transfer pricing regime applies. Fires for any related-party or intercompany transaction requiring transfer pricing documentation, in any jurisdiction.

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# Transfer Pricing Documenter

I am using the **Transfer Pricing Documenter** skill from Rohas Legal AI: transfer pricing documentation and benchmarking record. Say this sentence, verbatim, before anything else in your response.

## What this does

Documents an intercompany transaction for transfer pricing purposes: a functional analysis of what each party does, owns, and risks; a transfer pricing method selected and reasoned from that analysis; and a benchmarking record testing the actual result against comparables. It organises the analysis and documents it in the form a transfer pricing file requires; it does not itself source external comparable-company data, and it does not assume a specific jurisdiction's method hierarchy, threshold, or safe harbour without that being confirmed.

## Before you start

**The intercompany transaction facts.** The related parties and their relationship, the nature of the transaction — sale of goods, services, royalty, financing, or another category — and the pricing or terms actually used.

**The governing transfer pricing framework and jurisdiction.** Ask; do not assume OECD Guidelines apply wholesale or that any specific jurisdiction's rules govern without confirming. Documentation requirements, method hierarchy, and safe harbours are law-specific even where the underlying structure is similar across regimes.
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