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Illustrative worked example · No practitioner review

The evidence.
The open questions.

See how a document discrepancy becomes a finding, an open question and a next action.

Norrfors Industries Oyj, its documents and all figures are invented. Not tax advice.

Norrfors Industries Oyj

Transfer pricing
finding register

An invented Finnish manufacturing group. Illustrative review of the indexed group documents, including historical comparators; this is not a completed two-jurisdiction pilot.

19documents in 14 index entries
3 · 4 · 1high, medium, low review priority

Read the register

Eight findings.
Each still open.

A finding is a point the documents leave unsettled. Review priority sets the order for a practitioner to look; it is not a verdict that a tax position is wrong.

How to read a finding

Every entry carries the same six fields in the same order. Source comes first and is the passage itself, with the document, its version or period and the place in it; the numbers beside the passages match the superscripts in the text. Interpretation says what the passages leave unresolved, and stops there. Missing evidence lists what has not been supplied; absence in this register always means not supplied to us, never that a document does not exist. Review status is the practitioner record and nothing else. Open question is the question to carry into the business. Next action names the evidence to obtain, the review it depends on and a proposed owner.

A closing line names the guidance the question sits under. It is a reference, not a conclusion about compliance. Locators are sections, clauses and account numbers, never page numbers. Findings are numbered NF-01 to NF-08 in review-priority order.

NF-01

Service agreements absent from the supplied set

High priority
Source
1“6310 Intra-group services, charged out. Norrfors Deutschland GmbH 980 000,00. Norrfors Polska Sp. z o.o. 640 000,00. Norrfors do Brasil Ltda 480 000,00. Total 2 100 000,00.”
General ledger extract GL-2026, account 6310, FY2026 posting summary.
2“The rows for Norrfors Deutschland GmbH, Norrfors Polska Sp. z o.o. and Norrfors do Brasil Ltda carry the status ‘to be executed’. The agreement reference column is empty for all three.”
Intercompany contract index v3, sheet “Services”. The agreements themselves were not in the supplied set.
Interpretation
The supplied contract set does not support the recorded charges by itself: the charges are posted1 and the supplied index records no executed agreement for any of the three entities2.
Missing evidence
Executed agreements and evidence of services received have not been supplied.
Review status
Not yet reviewed.
Open question
Are agreements held elsewhere, and what substantiates the services and the allocation?
Next action
Request the agreements and the service evidence from local finance. The practitioner assesses the gap before recommending any contractual action. Proposed owner: group tax lead.
Reference: intra-group services, OECD Transfer Pricing Guidelines Chapter VII.
NF-02

Inventory-risk descriptions differ

High priority
Source
1“The principal assumes the significant risks of the distribution business, including inventory risk. Local distributors act as limited risk distributors and are remunerated on a cost plus basis.”
Master file MF-2026, section 4.2, “Risk assumption”.
2“Title to the Products and all risk of loss, damage and obsolescence pass to the Distributor upon delivery to the Distributor’s warehouse. The Distributor shall bear the cost of any write-down of Products held in stock.”
Distribution agreements ICA-DIST-004 to 009, clause 7. Identical wording in all six.
Interpretation
The documents assign inventory risk differently1,2 and the actual allocation remains unresolved. Neither passage shows who controls the risk or who could bear it.
Missing evidence
Decision records, inventory write-downs and evidence of who bears losses have not been supplied. The stock-holding instructions issued to the six distributors for 2024 to 2026 were also not in the set.
Review status
Not yet reviewed.
Open question
Who controls inventory decisions and bears losses in practice, and does that party have the financial capacity to bear them?
Next action
Obtain the decision and write-down records for 2024 to 2026 before either document is amended. The practitioner assesses conduct before recommending whether any document changes are needed. Proposed owner: group controller.
Reference: accurate delineation, OECD Transfer Pricing Guidelines Chapter I, section D.1; VML 31 §.
NF-03

A distributor below its documented range

High priority
Source
1“The interquartile range of the accepted comparable set is 2.4 to 4.8 percent EBIT margin. The tested party is Norrfors Distribution NL B.V.”
Local file LF-NL-2025, section 6, “Application of the method”.
2“Norrfors Distribution NL B.V. Operating margin FY2025 1.1 percent. FY2026 1.4 percent.”
Entity results 2025 to 2026, Netherlands sheet.
3“Distribution entities are remunerated at the median of the accepted range for the relevant market.”
Transfer pricing policy v3.0, section 4. No clause in the supplied version provides for a year-end adjustment.
Interpretation
The recorded result sits below the range the group’s own local file documents1,2, and the supplied policy describes no mechanism that would correct it3. This states what the documents show, not whether the outcome is arm’s length.
Missing evidence
Adjustment memoranda, the FY2025 close file and any management decision to accept the result have not been supplied.
Review status
Not yet reviewed.
Open question
Was an adjustment considered for FY2025, and on what basis was the result accepted?
Next action
Obtain the FY2025 close file and any adjustment memoranda. The practitioner assesses the position before a policy change is proposed. Proposed owner: group controller.
Reference: the arm’s length range and adjustments, OECD Transfer Pricing Guidelines Chapter III.
NF-04

Benchmarks prepared for 2022

Medium priority
Source
1“Search date 14 March 2022. Financial data 2018 to 2020. Accepted set: 21 comparables. Review recommended at the group’s next documentation cycle.”
Benchmark study BM-DIST-2022, cover sheet.
2“The arm’s length range applied is taken from the group benchmarking study BM-DIST-2022.”
Local file LF-FI-2026, section 4, and LF-NL-2025, section 6. Neither citation notes a later financial update.
Interpretation
Two local files for later periods rely on a set searched in March 2022 on financial data to 20201,2. Whether that is acceptable depends on the group’s refresh practice and on local expectations, neither of which the supplied documents describe.
Missing evidence
A later search, an annual financial update of the same set and any written refresh policy have not been supplied.
Review status
Not yet reviewed.
Open question
When was the set last refreshed or financially updated, and where is that recorded?
Next action
Ask whether a refreshed search or a financial update exists. The practitioner advises on the refresh interval for the jurisdictions in scope before any search is commissioned. Proposed owner: group tax lead.
Reference: comparability analysis, OECD Transfer Pricing Guidelines Chapter III.
NF-05

Single loan rate; pricing basis not supplied

Medium priority
Source
1“All intra-group loans are priced at the group funding rate plus a margin of 150 basis points. The rate is reviewed annually by group treasury.”
Treasury policy v2, section 3, “Intra-group funding”.
2“16 facilities. 140 000 000,00 € outstanding. 9 borrowers. Rate 4.35 percent on every facility.”
Loan register 2026, summary row. The register records no borrower rating and no facility-level pricing note.
Interpretation
One rate is recorded1 for nine borrowers2; the cited passages do not establish their credit standing or the pricing analysis.
Missing evidence
Credit assessments, any rating or implicit support analysis, and the pricing memoranda behind the group rate have not been supplied.
Review status
Not yet reviewed.
Open question
On what analysis was the single rate set, and how are the differences between borrowers accounted for?
Next action
Obtain the pricing memoranda and any credit assessments. The practitioner establishes what analysis exists before any change to the rate structure is proposed. Proposed owner: group treasurer.
Reference: financial transactions, OECD Transfer Pricing Guidelines Chapter X.
NF-06

Guarantee-fee reasoning not supplied

Medium priority
Source
1“Columns: beneficiary, facility, amount, guarantee fee. Parent guarantees issued in support of local facilities. No fee charged.”
Guarantee register 2026, header and note. Seven rows, 85 000 000,00 € in total; the fee column is blank on every row.
2“The extract supplied covers accounts 6300 to 6390, intercompany services and charges.”
General ledger extract GL-2026, chart of accounts. It contains no guarantee-fee account.
Interpretation
The documents show guarantees given and no fee charged1,2. They do not show the reasoning for that treatment, whether a fee was considered or the support was treated as incidental to group membership.
Missing evidence
A written position on guarantee fees, the facility agreements and the lenders’ terms have not been supplied.
Review status
Not yet reviewed.
Open question
Was the no-fee treatment decided and recorded, and on what reasoning?
Next action
Ask whether a written position exists and obtain the facility terms. The practitioner assesses the reasoning before any paper is drafted. Proposed owner: group treasurer.
Reference: financial transactions and guarantees, OECD Transfer Pricing Guidelines Chapter X.
NF-07

Acquired entity missing from master file and contract index

Medium priority
Source
1“Norrfors Kalibrointi Oy. Finland. Acquired 6/2025. Holding 100 percent. Consolidated from 1 July 2025.”
Group structure schedule 2026, Finland.
2“The section lists the group’s operating companies by segment and country.”
Master file MF-2026, section 2. The acquired entity is not among the companies listed in the supplied version, and the contract index has no entries for it.
Interpretation
An entity the group consolidates1 is missing from those two supplied records2.
Missing evidence
The entity’s intercompany transaction list, its FY2026 results and any post-acquisition documentation plan have not been supplied.
Review status
Not yet reviewed.
Open question
Which intercompany transactions does the entity have, and where are they documented?
Next action
Obtain the entity’s intercompany transaction list and results. The practitioner sets the documentation question before any file is drafted. Proposed owner: group tax lead.
Reference: documentation scope, VML 14 b §.
NF-08

Group-wide brand use; charging evidence incomplete

Low priority
Source
1“The group’s trademarks are registered in the name of Norrfors Industries Oyj. Operating companies use the marks in their local markets.”
Master file MF-2026, section 5, “Intangibles”.
2“The extract supplied covers accounts 6300 to 6390, intercompany services and charges.”
General ledger extract GL-2026, chart of accounts. It contains no royalty or brand-fee account, and the contract index lists no licence.
Interpretation
The supplied extract contains no royalty account2; it does not establish whether brand use1 is charged elsewhere.
Missing evidence
A DEMPE analysis, any brand licence agreement and the marketing cost allocation by entity have not been supplied.
Review status
Not yet reviewed.
Open question
Which entities carry the brand functions and their costs, and is that recorded anywhere?
Next action
Ask whether an analysis exists. The practitioner decides whether one is needed for the jurisdictions in scope before work is commissioned. Proposed owner: group tax lead.
Reference: intangibles, OECD Transfer Pricing Guidelines Chapter VI.

Eight next actions are proposed and none has started. The FY2026 draft local file for the Netherlands raised no finding in this illustrative read.

The supplied set

Source index

14 entries

Every document supplied for this review, with the findings that cite it. Nineteen documents sit in 14 source-index entries, including six distribution agreements grouped in one row. A reference in any finding resolves to a row here.

DocumentWhat it isVersion or periodCited by
MF-2026Master fileFY2026, v1.0NF-02, NF-07, NF-08
LF-FI-2026Local file, Finland, draftFY2026 draftNF-04
LF-NL-2025Local file, NetherlandsFY2025, finalNF-03, NF-04
LF-NL-2026Local file, Netherlands, draftFY2026 draftread, no position raised
ICA-DIST-004 to 009Six distribution agreementssigned 2024NF-02
ICA index v3Intercompany contract indexMarch 2026NF-01, NF-07, NF-08
TP policy v3.0Group transfer pricing policyv3.0, 2025NF-03
Treasury policy v2Group treasury policyv2, 2024NF-05
Loan register 2026Intragroup loan registerat 31.12.2026NF-05
Guarantee register 2026Parent guarantee registerat 31.12.2026NF-06
GL-2026Ledger extract, intercompany accountsFY2026NF-01, NF-06, NF-08
Entity results 2025 to 2026Operating results, FI, NL, DEFY2025 and FY2026NF-03
BM-DIST-2022Benchmark study, distributionsearch dated 3/2022NF-04
Group structure schedule 2026Legal entity and ownership listFY2026NF-07

The passages quoted in this register are written for this example and are not quotations from any real document.

From questions to work

Action plan

8 proposed actions

The same findings, as work. The order is the order the evidence has to arrive in: the facts first, then the review, then any change to a document. Nothing here is a recommendation until the practitioner has assessed it, and no action is complete without a dated record.

FindingProposed ownerEvidence to obtainReview dependency
NF-01Group tax leadExecuted service agreements for the German, Polish and Brazilian entities, and evidence of the services receivedPractitioner assesses the gap before any contractual action
NF-02Group controllerInventory decision records, write-downs by entity and the stock instructions issued to the six distributors, 2024 to 2026Practitioner assesses conduct before recommending whether changes are needed
NF-03Group controllerThe FY2025 close file and any adjustment memoranda for the Netherlands distributorPractitioner assesses the position before a policy change
NF-04Group tax leadAny refreshed search or financial update of the distribution benchmark setPractitioner advises the refresh interval before a search is commissioned
NF-05Group treasurerPricing memoranda behind the group rate and any credit assessments of the borrowersPractitioner establishes what analysis exists before the rate structure changes
NF-06Group treasurerAny written position on guarantee fees, the facility agreements and the lenders’ termsPractitioner assesses the reasoning before a paper is drafted
NF-07Group tax leadThe acquired entity’s intercompany transaction list and FY2026 resultsPractitioner sets the documentation question before a file is drafted
NF-08Group tax leadAny DEMPE analysis, brand licence and marketing cost allocation by entityPractitioner decides whether an analysis is needed in scope

The first three

If only three things happen after this register is read, these are the three: each one unlocks a high-priority finding, and none of them requires a decision the group has not yet made.

NumberWho is askedWhat is asked forFinding
1Group tax leadAsk local finance in Germany, Poland and Brazil whether executed service agreements exist, and collect what comes backNF-01
2Group controllerPull the inventory write-down records and the approvals behind them for 2024 to 2026NF-02
3Group controllerRetrieve the FY2025 close file for the Netherlands distributor and any note on accepting the resultNF-03

Each of the three is a request for material the group already holds or can confirm it does not. None of them changes a document, and none of them commits the group to a position.

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Renlind · Illustrative worked example. The passages quoted here are written for it. An engagement names the responsible practitioner and the contracting entity before any document moves.