// Tax
Transfer pricing without the Big Four bill
By Fincrove Partners · Mar 2026 · 6 min read
For most cross-border groups under €50m of revenue, a full Big Four transfer pricing study is overkill. What tax authorities actually want is a coherent, contemporaneous file that explains why the prices charged between related parties are arm's length.
The minimum defensible file
- A functional analysis: who does what, who owns what, who bears which risks.
- A method selection memo (TNMM, CUP, cost-plus) with the reasoning written down.
- Benchmarking, a public-database search refreshed every three years for stable structures.
- Intercompany agreements that match the actual flows and pricing.
- An annual update memo that confirms nothing material has changed.
Done well, this sits in a single binder. Done badly, it sits in 200 pages no one reads. The audit defence value is identical.