86 Transfer Pricing Success Criteria

What is involved in Transfer Pricing

Find out what the related areas are that Transfer Pricing connects with, associates with, correlates with or affects, and which require thought, deliberation, analysis, review and discussion. This unique checklist stands out in a sense that it is not per-se designed to give answers, but to engage the reader and lay out a Transfer Pricing thinking-frame.

How far is your company on its Transfer Pricing journey?

Take this short survey to gauge your organization’s progress toward Transfer Pricing leadership. Learn your strongest and weakest areas, and what you can do now to create a strategy that delivers results.

To address the criteria in this checklist for your organization, extensive selected resources are provided for sources of further research and information.

Start the Checklist

Below you will find a quick checklist designed to help you think about which Transfer Pricing related domains to cover and 86 essential critical questions to check off in that domain.

The following domains are covered:

Transfer Pricing, Accounting system, Amicus curiae, Arm’s length principle, Business development, Corporate tax, Customs duties, EU Joint Transfer Pricing Forum, Economies of scale, Ernst & Young, Formulary apportionment, Global Financial Integrity, Import quotas, Internal Revenue Service, Marginal revenue, Marginal utility, Multinational corporation, Nonrecognition provisions, organization for Economic Co-operation and Development, Performance measurement, Profit maximization, Transactional net margin method, U.S. Supreme Court, Value added tax, Withholding tax:

Transfer Pricing Critical Criteria:

Deduce Transfer Pricing management and define what do we need to start doing with Transfer Pricing.

– Is Comparability of Transactions to be Based on Single Transactions or Groupings of Transactions?

– Are transfer pricing disputes about the facts, the applicable law and/or the economics?

– Why and how are support department costs allocated to operating departments?

– Under what conditions might negotiating a transfer price be successful?

– Should the chosen fixed-cost rates be actual or budgeted?

– Does transfer pricing re-introduce transactions costs?

– Does top management have a transfer pricing policy?

– How can we measure profitablity for our customers?

– How does the firm measure investment?

– What is a Management Control System?

– How does the firm measure revenues?

– How are revenue variances computed?

– State Transfer Pricing Adjustments?

– Why are transfer prices used?

– Who sets the transfer prices?

– What is a transfer price?

– Which method applies?

Accounting system Critical Criteria:

Scan Accounting system engagements and cater for concise Accounting system education.

– A compounding model resolution with available relevant data can often provide insight towards a solution methodology; which Transfer Pricing models, tools and techniques are necessary?

– What is the source of the strategies for Transfer Pricing strengthening and reform?

– Do all accounting systems require using debits and credits?

– Does the Transfer Pricing task fit the clients priorities?

Amicus curiae Critical Criteria:

Apply Amicus curiae leadership and oversee implementation of Amicus curiae.

– Risk factors: what are the characteristics of Transfer Pricing that make it risky?

– Have you identified your Transfer Pricing key performance indicators?

– Does our organization need more Transfer Pricing education?

Arm’s length principle Critical Criteria:

Exchange ideas about Arm’s length principle engagements and perfect Arm’s length principle conflict management.

– What other organizational variables, such as reward systems or communication systems, affect the performance of this Transfer Pricing process?

– Is there a Transfer Pricing Communication plan covering who needs to get what information when?

Business development Critical Criteria:

Check Business development adoptions and define what do we need to start doing with Business development.

– Why is it important to have senior management support for a Transfer Pricing project?

– How do we go about Comparing Transfer Pricing approaches/solutions?

Corporate tax Critical Criteria:

Bootstrap Corporate tax risks and reinforce and communicate particularly sensitive Corporate tax decisions.

– How do mission and objectives affect the Transfer Pricing processes of our organization?

– What will drive Transfer Pricing change?

– Is the scope of Transfer Pricing defined?

Customs duties Critical Criteria:

Troubleshoot Customs duties goals and achieve a single Customs duties view and bringing data together.

– What are the top 3 things at the forefront of our Transfer Pricing agendas for the next 3 years?

– Will Transfer Pricing deliverables need to be tested and, if so, by whom?

– How to deal with Transfer Pricing Changes?

EU Joint Transfer Pricing Forum Critical Criteria:

Focus on EU Joint Transfer Pricing Forum projects and find the ideas you already have.

– What vendors make products that address the Transfer Pricing needs?

Economies of scale Critical Criteria:

Have a meeting on Economies of scale planning and report on developing an effective Economies of scale strategy.

– Marketing budgets are tighter, consumers are more skeptical, and social media has changed forever the way we talk about Transfer Pricing. How do we gain traction?

– Are assumptions made in Transfer Pricing stated explicitly?

Ernst & Young Critical Criteria:

Rank Ernst & Young quality and achieve a single Ernst & Young view and bringing data together.

– At what point will vulnerability assessments be performed once Transfer Pricing is put into production (e.g., ongoing Risk Management after implementation)?

– Do we aggressively reward and promote the people who have the biggest impact on creating excellent Transfer Pricing services/products?

– Are there Transfer Pricing Models?

Formulary apportionment Critical Criteria:

Have a round table over Formulary apportionment projects and summarize a clear Formulary apportionment focus.

– What are your results for key measures or indicators of the accomplishment of your Transfer Pricing strategy and action plans, including building and strengthening core competencies?

– Is Supporting Transfer Pricing documentation required?

Global Financial Integrity Critical Criteria:

Guide Global Financial Integrity decisions and work towards be a leading Global Financial Integrity expert.

– Who are the people involved in developing and implementing Transfer Pricing?

– Who sets the Transfer Pricing standards?

Import quotas Critical Criteria:

Cut a stake in Import quotas management and cater for concise Import quotas education.

– What are the disruptive Transfer Pricing technologies that enable our organization to radically change our business processes?

– Do Transfer Pricing rules make a reasonable demand on a users capabilities?

– How much does Transfer Pricing help?

Internal Revenue Service Critical Criteria:

Deliberate Internal Revenue Service tactics and oversee Internal Revenue Service requirements.

– What is the total cost related to deploying Transfer Pricing, including any consulting or professional services?

– Do we have past Transfer Pricing Successes?

– How do we keep improving Transfer Pricing?

Marginal revenue Critical Criteria:

Gauge Marginal revenue risks and point out Marginal revenue tensions in leadership.

– Think about the people you identified for your Transfer Pricing project and the project responsibilities you would assign to them. what kind of training do you think they would need to perform these responsibilities effectively?

– Do we all define Transfer Pricing in the same way?

– What are current Transfer Pricing Paradigms?

Marginal utility Critical Criteria:

Be clear about Marginal utility goals and give examples utilizing a core of simple Marginal utility skills.

– What management system can we use to leverage the Transfer Pricing experience, ideas, and concerns of the people closest to the work to be done?

– What are your key performance measures or indicators and in-process measures for the control and improvement of your Transfer Pricing processes?

Multinational corporation Critical Criteria:

Own Multinational corporation quality and probe using an integrated framework to make sure Multinational corporation is getting what it needs.

– Will new equipment/products be required to facilitate Transfer Pricing delivery for example is new software needed?

– How can you measure Transfer Pricing in a systematic way?

– Why should we adopt a Transfer Pricing framework?

Nonrecognition provisions Critical Criteria:

Examine Nonrecognition provisions adoptions and diversify by understanding risks and leveraging Nonrecognition provisions.

– Does Transfer Pricing include applications and information with regulatory compliance significance (or other contractual conditions that must be formally complied with) in a new or unique manner for which no approved security requirements, templates or design models exist?

– Consider your own Transfer Pricing project. what types of organizational problems do you think might be causing or affecting your problem, based on the work done so far?

– What will be the consequences to the business (financial, reputation etc) if Transfer Pricing does not go ahead or fails to deliver the objectives?

organization for Economic Co-operation and Development Critical Criteria:

Prioritize organization for Economic Co-operation and Development tasks and optimize organization for Economic Co-operation and Development leadership as a key to advancement.

– What is the purpose of Transfer Pricing in relation to the mission?

– How do we manage Transfer Pricing Knowledge Management (KM)?

Performance measurement Critical Criteria:

Read up on Performance measurement goals and transcribe Performance measurement as tomorrows backbone for success.

– Constantly communicate the new direction to staff. HR must rapidly readjust organizational charts, job descriptions, workflow processes, salary levels, performance measurement, etc. Why?

– Performance measurement system design: Should process based approaches be adopted?

– The performance measurement revolution: why now and what next?

– Are accountability and ownership for Transfer Pricing clearly defined?

– How do we maintain Transfer Pricings Integrity?

Profit maximization Critical Criteria:

Check Profit maximization outcomes and reinforce and communicate particularly sensitive Profit maximization decisions.

– Who will be responsible for making the decisions to include or exclude requested changes once Transfer Pricing is underway?

– Which Transfer Pricing goals are the most important?

Transactional net margin method Critical Criteria:

Devise Transactional net margin method projects and look for lots of ideas.

– How likely is the current Transfer Pricing plan to come in on schedule or on budget?

– How important is Transfer Pricing to the user organizations mission?

U.S. Supreme Court Critical Criteria:

Detail U.S. Supreme Court goals and define what do we need to start doing with U.S. Supreme Court.

– What are our best practices for minimizing Transfer Pricing project risk, while demonstrating incremental value and quick wins throughout the Transfer Pricing project lifecycle?

– What are the Essentials of Internal Transfer Pricing Management?

Value added tax Critical Criteria:

Have a session on Value added tax engagements and achieve a single Value added tax view and bringing data together.

– In a project to restructure Transfer Pricing outcomes, which stakeholders would you involve?

– Can Management personnel recognize the monetary benefit of Transfer Pricing?

Withholding tax Critical Criteria:

Think about Withholding tax engagements and integrate design thinking in Withholding tax innovation.

– Can we add value to the current Transfer Pricing decision-making process (largely qualitative) by incorporating uncertainty modeling (more quantitative)?


This quick readiness checklist is a selected resource to help you move forward. Learn more about how to achieve comprehensive insights with the Transfer Pricing Self Assessment:


Author: Gerard Blokdijk

CEO at The Art of Service | http://theartofservice.com



Gerard is the CEO at The Art of Service. He has been providing information technology insights, talks, tools and products to organizations in a wide range of industries for over 25 years. Gerard is a widely recognized and respected information expert. Gerard founded The Art of Service consulting business in 2000. Gerard has authored numerous published books to date.

External links:

To address the criteria in this checklist, these selected resources are provided for sources of further research and information:

Transfer Pricing External links:

[PDF]Introduction to Transfer Pricing: The Basics – BKD

[PDF]Chapter 1 An Introduction to Transfer Pricing – United …

GENERAL BIBLIOGRAPHY – Transfer Pricing Network

Accounting system External links:


Energy Accounting System (EAS)

Accounting Software | Accounting System | Open Systems

Amicus curiae External links:

Amicus Curiae – Merriam-Webster
https://www.merriam-webster.com/dictionary/amicus curiae

[PDF]Request to File Amicus Curiae Brief – Thayer

Amicus curiae legal definition of amicus curiae

Business development External links:

Small Business Development – Miami-Dade County

dslbd | Department of Small and Local Business Development

Corporate tax External links:

Corporate Tax: Eliminate It | National Review

Corporate Tax Forms – Arizona Department of Revenue

Customs duties External links:

Duties and taxes, import customs duties, pay customs …

Customs duties legal definition of customs duties

EU Joint Transfer Pricing Forum External links:

EU Joint Transfer Pricing Forum – WOW.com

EU Joint Transfer Pricing Forum Archives – Thomson …


Economies of scale External links:

Economies of Scale: Definition, Types – The Balance

Economies of scale Flashcards | Quizlet

Low-Cost Producer or Economies of Scale

Ernst & Young External links:

Ernst & Young Global Careers – Oracle

Formulary apportionment External links:


Another Voice for Formulary Apportionment | Bloomberg …

Global Financial Integrity External links:

About « Global Financial Integrity

Reports « Global Financial Integrity

Global Financial Integrity – Home | Facebook

Import quotas External links:

Commodities Subject to Import Quotas | U.S. Customs …

Import Quotas legal definition of Import Quotas

Internal Revenue Service External links:

Internal Revenue Service (IRS) | U.S. Government Bookstore

Forms and Instructions (PDF) – Internal Revenue Service


Marginal revenue External links:

Marginal revenue – How is Marginal revenue abbreviated?

What is MARGINAL REVENUE – Black’s Law Dictionary

How to Calculate Marginal Revenue | Chron.com

Marginal utility External links:

Law Of Diminishing Marginal Utility

Marginal Utility Level 3 Flashcards | Quizlet

How to Calculate Marginal Utility: 11 Steps (with Pictures)

Multinational corporation External links:


Multinational Corporation – MNC – Investopedia

multinational corporation – Everything2.com

Performance measurement External links:

[PDF]OJP Performance Measurement Platform Log-In …

Performance Measurement Dashboard | City of Tampa

Performance Measurement | Joint Commission

Profit maximization External links:

What is Profit Maximization? definition and meaning

Profit / Profit Maximization Flashcards | Quizlet

Profit Maximization Flashcards | Quizlet

Transactional net margin method External links:

Transactional net margin method – Revolvy
https://www.revolvy.com/topic/Transactional net margin method

U.S. Supreme Court External links:

U.S. Supreme Court – The New York Times

Value added tax External links:

Value Added Tax Act – AbeBooks

Value added tax (Book, 1978) [WorldCat.org]

What is value added tax – Answers.com

Withholding tax External links:

Withholding Tax – Mississippi

[PDF]2018 Minnesota Withholding Tax Tables

Arizona Withholding Tax

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