In a recent episode of The Transfer Pricing Method, host Adriaan van der Heijden spoke with Mariia Aspidova, Group Tax Director at Expondo, about the practical challenges in-house tax and transfer pricing professionals face when stepping into a multinational environment. Their discussion covered transfer pricing backlogs, documentation consistency, policy implementation, stakeholder management, and audit readiness. Below are the key takeaways.
In practice, transfer pricing professionals joining a new multinational often inherit a transfer pricing backlog. That backlog can take different forms. In some cases, there may be no transfer pricing policies and documentation at all. In others, local files exist, but supporting documentation is incomplete, benchmarks are outdated, or key materials are missing.
The practical response is not to start drafting new documents immediately. The first step is to understand what is already in place, what is missing, and whether the existing materials actually reflect the group’s operational reality. That means assessing whether the documented functional profile, risk allocation, and transaction flows match the real business.
A strong transfer pricing file is not simply a package of standard deliverables. It must reflect the actual business. Maria stressed the importance of diving into the operational setup first. What are the facts and circumstances? Which functions are performed where? Which risks are borne by which entity? Which assets are actually used? And how does all of that connect to the documentation already on file?
This also means checking whether the broader documentation package is complete. Local files, master files, benchmarks, intercompany agreements, invoices, and supporting materials all play a role. If the underlying evidence is weak, even a technically well-written transfer pricing report may not stand up under scrutiny.
For large multinationals, consistency is one of the hardest parts of transfer pricing documentation. Different countries and entities, different local teams, and different advisors can all create inconsistencies in language, positioning, and factual descriptions. That can become a serious issue once tax authorities start comparing files across jurisdictions.
A practical solution discussed in the episode is to work from one common source of truth. Maria described an approach in which the central entrepreneur file effectively serves as the starting point, with relevant sections then adapted for local use. Whether this is done through templates, centralized preparation, or specialized tooling, the core principle stays the same: the source information must be aligned, and the person responsible for transfer pricing must guard that consistency carefully.
In-house professionals cannot approach transfer pricing as a purely theoretical exercise. A policy may look robust on paper and still fail in practice if the business cannot actually implement it.
That is why advisors should go beyond designing the policy itself. They should also think through the operational reality with their clients. Is the required information available? Are allocation keys accessible? Can the ERP system support the intended charging model? If not, what interim steps are possible? What is the fallback if the original implementation route does not work?
For in-house teams, the message is similar. Do not stop once the policy is written. Walk through the implementation path in detail with your advisors. That exercise often reveals blockers early and makes it easier to build a workable model rather than an idealized one.
Another valuable point from the conversation was that a transfer pricing policy should not only reflect the current structure. It should also support where the business is going. Legacy policies should be assessed at both entity and transaction level, while taking future strategies into account.
That requires a more forward-looking perspective. Which entities may take on additional functions in the future? Which entities are capable of performing them? How should those activities be priced? And how will these developments affect the overall characterisation of the entities involved?
This matters because transfer pricing should not merely document yesterday’s structure. It should also help the business move into tomorrow’s structure in a controlled and defensible way.
Sometimes policy changes can be justified, for example after a major acquisition, restructuring, or a significant shift in the business. But where there is no clear commercial reason, inconsistency becomes a risk that should be dealt with directly.
Transfer pricing does not sit in isolation. It requires input, support, and awareness across the organization. Transfer pricing requires involvement from C-level stakeholders, finance & tax, and business teams. It depends on timely information, action, and alignment across the organization.
That makes communication a core part of the in-house role. Professionals need to be able to explain why transfer pricing matters and what information is needed. In practice, that often means building visibility for the function inside the business and ensuring stakeholders understand the consequences of late involvement. This is especially important in large restructurings and M&A transactions. Tax and transfer pricing teams are often brought in late, once the commercial decision has already been made. This can then have a significant financial and tax impact on the business.
Audit readiness is not about outsourcing a local file or benchmark study on short notice. To be audit-ready, groups should already know the business story they want to defend. Intercompany agreements, invoices, calculations, adjustment mechanics, and the underlying rationale should be prepared and understood before tax authorities ask questions. Otherwise, the group risks trying to reconstruct key evidence after the fact, which is far more difficult and far less credible.
The discussion also highlighted an important final point: local requirements matter. In some jurisdictions, formalities around timing, execution, or stamping of documentation can be critical. Even when the operational position is strong, missing a local requirement can still create exposure.
Transfer pricing is about much more than drafting policies and preparing documentation. It is about understanding how the business really works, translating that into a consistent and defensible framework, and making sure the framework can actually be implemented. For in-house teams, that means balancing technical quality with operational reality. For advisors, it means looking beyond the policy itself and helping clients navigate the full path from design to execution. When both sides get that balance right, transfer pricing becomes far more robust, more practical, and far better prepared for scrutiny.
Polish transfer pricing regulations adopt a broad and sometimes non-obvious approach to defining what constitutes a controlled transaction. As a result, taxpayers in Poland may find that arrangements they would not typically associate with transfer pricing, may, in fact, fall within the scope of documentation and reporting obligations. Transfer pricing is often associated with recurring, […]
Quantera Global is proud to announce that BREICIS has joined the Quantera Global Network as its alliance partner in Latvia. This strategic cooperation further strengthens Quantera Global’s presence in the Baltic region and enhances the network’s ability to support clients with high-quality, practical, and internationally coordinated transfer pricing and tax advisory services. Quantera Global Quantera […]
On 13 May 2026, the Court of Justice of the European Union (CJEU) released its judgment in the Stellantis Portugal case. The case addresses a topic that has been debated for years within multinational groups, transfer pricing teams, and indirect tax specialists alike: Can a transfer pricing adjustment trigger VAT? At first sight, this may […]