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Transfer Pricing: Functional Analysis Checklist - R&D | 转让定价: 企业功能分析表 - 研发

Updated: Feb 12

Functional analysis plays an important role in the preparation of transfer pricing documentation.


The importance of functional analysis can be attributed to the fact that it provides an overview of value creation within the supply chain, particularly related party transactions. It provides information on each party to a transaction regarding:

  • the relative functions performed.

  • the assets used; and

  • the responsibility for the risks they assume in the creation of total value.

In most cases, a functional analysis is carried out during an interview for a functional analysis or during a conversation for a functional analysis.