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July 10, 2024
15 min read

The Ultimate Guide to Transfer Pricing Functional Interviews

Borys Ulanenko

Borys Ulanenko

CEO at ArmsLength AI

The Ultimate Guide to Transfer Pricing Functional Interviews

TL;DR - Key Takeaways

  • Functional interviews are critical for gathering facts about functions, assets, and risks to support compliant transfer pricing documentation.
  • A structured methodology ensures comprehensive coverage of all relevant areas, from preparation through documentation.
  • Special techniques are needed to uncover DEMPE functions (Development, Enhancement, Maintenance, Protection, Exploitation) for valuable intangibles.
  • Conducting interviews across departments provides the 360-degree view needed to accurately delineate controlled transactions.
  • The insights from functional interviews directly feed into a defensible functional analysis that aligns profit allocation with value creation.

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