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July 10, 2024
15 min read
The Ultimate Guide to Transfer Pricing Functional Interviews

Borys Ulanenko
CEO at ArmsLength AI

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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