There is not one set of requirements that applies to all transfer pricing agreements in all jurisdictions. Even the OECD does not provide specific guidance on what information must be included in transfer pricing agreements. This makes sense; they are providing guidance for countries around the world, with different legal systems and focus areas.
Moreover, there is tremendous freedom for private parties to design agreements (freedom of contract). Our agreements contain all the essential aspects such as parties, scope, controlled transaction and arm’s length remuneration and give clear instructions. Other than that, the agreements can be adjusted to suit your needs.
