Key Functions of a Transfer Pricing Advisor

June 28, 2024


In the global business world, Transfer Pricing plays a crucial role in tax optimization and financial transparency. Transfer Pricing Advisors are specialized professionals who guide companies in complying with regulations and implementing tax-efficient strategies.  

Evaluation of Intercompany Transactions

One of the primary roles of a Transfer Pricing Advisor is the evaluation of intercompany transactions. This process includes the detailed analysis of transactions between related entities to ensure that they are conducted at arm’s length, complying with the arm’s length principles established by OECD guidelines and tax authorities. As part of this process, the Transfer Pricing advisor has the ability to perform preventive analysis to reduce or minimize any tax exposure of the taxpayer.  

Documentation and Compliance

The transfer pricing advisor is also responsible for preparing the necessary documentation to support the company’s transfer pricing policies. This includes local and master reports that must comply with international regulations, such as OECD guidelines, and the specific regulations of each country where the company operates. Additionally, and in accordance with international standards and regulatory requirements, the Transfer Pricing advisor has the capacity to prepare the so-called Country by Country Reports, which must be submitted mainly by the parent companies of multinational groups, under the fulfillment of certain requirements.  

Comparative Analysis and Market Studies

In order to determine appropriate Transfer Pricing, the advisor performs comparative analysis and market range studies. This work involves the collection and evaluation of data from comparable companies to establish benchmarks that ensure the determination of appropriate returns and/or prices in intercompany transactions.  

International Tax Planning

Transfer Pricing advisors play a strategic role in international tax planning. They help companies design tax structures that optimize the global tax burden while ensuring compliance with tax laws in all relevant jurisdictions.  

Defense and Dispute Resolution

In case of tax audits or disputes with tax authorities, the Transfer Pricing Advisor acts as an advocate for the company. He prepares defense strategies and participates in dispute resolution, ensuring that the company is protected and its Transfer Pricing policies are adequately defended.  

Training and Continuing Education

Finally, a Transfer Pricing advisor must keep up to date with the latest regulations and trends in the international tax arena. This includes ongoing training and adapting company policies to regulatory changes and industry best practices.  


The role of the Transfer Pricing advisor is multifaceted and vital to the financial success of multinational companies. From transaction evaluation to audit defense, these professionals ensure that companies operate efficiently and comply with all relevant tax regulations.