The Risk Assessment Test does not constitute a full analysis of a company’s specific facts and circumstances.

1 / 14

Country of Incorporation

2 / 14

Does the company have related party dealings relating to intellectual property, services, or financing?

3 / 14

Which industry does the company operate in?

4 / 14

Do related party transactions amount to more than 50% of either Revenues or Costs for the Company?

5 / 14

Does the company have dealings with related parties located in tax havens?

6 / 14

Does the Company have and maintain at least one of the following types of documentation?

• Agreements with Related Parties
• Transfer Pricing documentation
• Defense file
• Transfer Pricing internal policies

7 / 14

Has the company or its corporate group been restructured in any of the last 4 years?

8 / 14

Has the Company incurred operating losses in any of the last 4 years?

9 / 14

Has the company experienced significant swings in its revenue and/or profitability in the last 4 years?

10 / 14

Has the Company amended any of its tax returns during the last 4 years?

11 / 14

Has the Company requested a tax refund during any of the last 4 years?

12 / 14

Are key personnel at the Company knowledgeable of its transfer pricing policies?

13 / 14

Is any related party transaction tested via gross margin methods (i.e., Resale Minus method price or Cost Plus method)?

14 / 14

Does the Company monitor and check its transfer pricing results before year-end?

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