Review the legal ownership and geographical location of operations.
Determine the drivers of profit, understand current markets, I/C service arrangements etc
Complete functional analysis to understand the functions performed by various divisions of the Group.
Identify the most important business risks at group level.
Understand what intangibles exist within the group, list and identify the intangibles relevant for TP purposes, understand what agreements are in place to use IP, understand the group policy on R&D, determine to what extent intangibles have been transferred or used by other connected persons.
Define and describe the controlled transaction.
Describe the functions performed by the tested party, the contribution to the overall supply chain.
Describe the risks borne by the tested party.
Select the most appropriate TP method based on assumptions and analysis performed at steps 1-4.
Select appropriate comparables.
Apply the results of the benchmarking and economic analysis to the facts of the relevant case.
Update the report incorporating the items referred to above.
Share the results with the client.