Margin Notes
Observations from the edges of Transfer Pricing Practice
Margin Notes is where we explore themes at the heart of the Transfer Pricing craft. These reflections are shaped by evolving guidance, economic undercurrents, and overlooked moments in economic analysis that can sharpen the formation of a policy or elevate documentation. Whether sparked by a headline, or inspired by long hours at the workbench, we bring insights with evident impact — always with clarity in mind. And, occasionally, with wit.
Riskier Business – Beyond Market & Transactional Risks
Most transfer pricing documentation overemphasizes transactional risks while collapsing strategic business risks into generic “market risk.” This Margin Note examines how the OECD Transfer Pricing Guidelines expect companies to identify, describe, and substantiate non-transactional risks—drawing directly from management’s own public risk disclosures—to strengthen Local and Master File defensibility.