TP Study
A structured functional, asset and risk analysis that forms the foundation of your transfer pricing position.
A transfer pricing study documents the functions performed, assets employed and risks assumed (FAR analysis) by each party to a related-party transaction, then uses this to select the most appropriate pricing method and characterise the tested party. It is the analytical backbone that supports both the benchmarking exercise and the Form 3CEB certification, and it's the first document reviewed in any transfer pricing assessment.
What a TP study involves
A study is built transaction by transaction, grounded in how the business actually operates, not just contractual terms.
- Conducting functional, asset and risk (FAR) analysis for each transaction
- Reviewing intercompany agreements against actual conduct
- Characterising the tested party for each transaction type
- Selecting the most appropriate arm's length pricing method
- Documenting industry and economic context
- Linking the study output into benchmarking and Form 3CEB
What this service includes
How we build your TP study.
FAR Analysis
Mapping functions, assets and risks across each party to the transaction.
Agreement Review
Comparing intercompany agreements against actual business conduct.
Tested Party Selection
Identifying the party whose margin is most reliably tested against comparables.
Method Selection
Choosing the pricing method best supported by the available data and facts.
Our process
From initial consultation to completion.
Information Gathering
Collecting agreements, financials, and operational details for each transaction.
FAR Analysis
Documenting the functions, assets and risks of each party involved.
Characterisation & Method Selection
Determining the tested party and the most defensible pricing method.
Study Finalisation
Compiling the study to feed directly into benchmarking and Form 3CEB.
Why the study matters more than it seems
What sets our approach apart.
It's the first thing assessing officers read
A weak or generic FAR analysis undermines credibility before the numbers are even discussed.
Substance over form is the real test
Authorities look at actual conduct, not just what agreements say — the study needs to reflect reality.
A good study makes benchmarking sharper
Correct characterisation narrows the comparable search to genuinely similar businesses, strengthening the outcome.
TP study questions answered
What people ask before engaging us.
Build a TP study that stands up to scrutiny.
Let our team help you navigate this process with clarity and confidence.
