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Transfer Pricing

Transfer Pricing Risk Assessment Services

A focused review of your related-party transactions to identify transfer pricing exposure — weak documentation, aggressive positions and audit triggers — before the department does.

Exposure ReviewAudit TriggersGap AnalysisRemediation
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Trusted Across Diverse Business Sectors

Gerresheimer
Leverage
Bureau Veritas
Ultrasyst Systems
UFLEX
Meitra Hospital
IRUS
JJJ Client
Kidys Bakery
MK Engineering Works
Bhanu Biotech
Saish Medical Solutions
Bio Petro Clean
Kartik Speciality Coatings
Delta Bioscience
TP Risk Assessment

Why assess transfer pricing risk proactively?

A risk assessment finds the weak points in your TP position — before a notice does — and shows what to fix.

Identify Exposure

Spotting transactions and positions most likely to attract adjustment.

  • High-value / cross-border deals
  • Intangibles and financing
  • Loss-making or margin outliers

Close the Gaps

Turning findings into a clear remediation and documentation plan.

  • Documentation gaps
  • Benchmarking weaknesses
  • Consistency across years
Important: Risk is highest where documentation is thin, margins are unusual or positions shift year to year.
TP Risk Perspective

Most transfer pricing adjustments are predictable — and preventable.

Transfer pricing scrutiny tends to focus on the same weak points: unusual margins, intangibles, intra-group financing and thin documentation.

A risk assessment tests your position against those triggers and quantifies the exposure before it becomes a demand.

Findings feed directly into documentation, benchmarking and, if needed, defence.

TP Risk Focus Areas

Where risk typically sits.

Margin Outliers
Intangibles
Intra-Group Loans
Documentation Gaps
Year-on-Year Consistency
Prior Adjustments
TP Risk Coverage

Transfer pricing risk work we commonly handle.

A risk review can be a one-off health check or a pre-assessment readiness exercise.

Exposure Mapping

Identifying and ranking transactions by adjustment risk.

Documentation Review

Testing whether existing documentation would hold up.

Benchmarking Check

Reviewing whether comparables and margins are defensible.

Remediation Plan

A clear plan to close gaps before the next assessment.

When a Risk Review Helps

Situations that warrant a check.

Before an Expected Audit

Fix exposure before scrutiny begins.

After a Prior Adjustment

Ensure the same issue does not recur.

New or Growing Transactions

Test positions as dealings scale up.

Group Restructuring

Re-check TP after structural change.

TP Risk Framework

Key areas a risk assessment tests.

Pricing

Support

Is each price supported by method and comparables?

Docs

Sufficiency

Is documentation complete, current and consistent?

Margins

Reasonableness

Do results sit within a defensible arm's-length range?

History

Consistency

Are positions consistent across years and entities?

How We Work

A focused risk-assessment process.

The review is scoped to the transactions that carry the most exposure.

01

Scope

Identify the transactions and years to review.

02

Test

Assess pricing, documentation and margins against triggers.

03

Quantify

Estimate the potential exposure and likelihood.

04

Prioritise

Rank issues by risk and cost to fix.

05

Plan

Set out clear remediation and documentation steps.

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Information Required

What we need for a risk review.

Related-party transaction list
Existing TP study and Form 3CEB
Segmental financials
Agreements for key transactions
Prior TP notices or adjustments
Group structure
Details of IP and financing
Margin / profitability data
Prevention & Cost

Fixing exposure early is far cheaper than an adjustment.

A transfer pricing adjustment brings additional tax, interest and potential penalty — often many times the cost of a proactive review.

Most exposure comes down to a few weak points that a focused assessment can identify and quantify.

Acting on the findings before assessment converts risk into a defensible, documented position.

Want to know your transfer pricing exposure before the department does?

Discuss a Risk Review
TP Risk Consultant

Why groups choose JJJ & Company LLP for TP risk.

Risk work is most valuable when findings flow into documentation and defence.

Trigger-Focused

We test against the issues officers actually raise.

Quantified Exposure

Risk is estimated, not just described.

Actionable Plan

Findings come with a clear remediation route.

Defence-Connected

Weak points are fixed with assessment in mind.

Frequently Asked Questions

Common TP risk questions.

What is a transfer pricing risk assessment?
It is a focused review of related-party transactions and documentation to identify where an adjustment is most likely, and to quantify and prioritise that exposure.
What transactions carry the most risk?
Typically intangibles and royalties, intra-group financing, high-value cross-border dealings and any position with unusual margins or thin documentation.
How is this different from documentation?
Documentation records and supports the position; a risk assessment stress-tests it to find and fix weaknesses before scrutiny.
Is it worth doing before an audit?
Yes. Identifying and remediating exposure before assessment is far cheaper than defending an adjustment after it is proposed.
What do you deliver?
A ranked view of exposure with an estimate of risk and a clear remediation and documentation plan.
What information is needed?
Your related-party transaction list, existing TP study and 3CEB, agreements, financials and any prior notices.
Reviewed by JJJ & Company LLP Chartered Accountancy Team · Last reviewed: August 2026
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