The end of October marks the deadline for businesses to prepare transfer pricing documentation, while TPR-C filings must be made by November 30. So it’s high time to carefully analyse your 2022 business operations with a view to checking if they need to be documented and avoiding severe consequences of non-compliance. Below we describe examples of untypical transactions that may be reportable for transfer pricing purposes.


Identifying your transfer pricing documentation obligations should preferably start with an in-depth analysis of how a controlled transaction is defined. In accordance with the CIT Act, controlled transactions are:


“operations of a business nature, including the attribution of income to a permanent establishment, that are identified on the basis of genuine conduct of the parties and whose terms have been determined or imposed due to associations”.


Intuitively, transfer pricing documentation requirements apply to such transactions as sale or purchase of goods or services and financial transactions (e.g. loans or cash pooling). But when ensuring TP documentation compliance for a specific tax year, you are advised to not only look into the typical transactions expressly made reportable by law or established practice, but also analyse untypical business operations that may not be among obvious candidates for the above definition and yet have to documented.

If you are interested in a full text in English or German, please contact use at