The international transaction is the unit of the file
OECD analysis does not start with a country. It starts with a controlled transaction: what was provided, by whom, under what contractual terms, with what FAR profile, and at what price. India's section 92B definition of international transaction (and the deemed international transaction rules) makes that unit statutory. The UAE CT regulations do the same for related-party and connected-person dealings that cross the disclosure thresholds.
Files go wrong when the transaction schedule is an afterthought. A single "management fee" line that actually bundles secondments, IT recharge, and a guarantee will produce one method, one PLI, and one set of comparables that fit none of the underlying deals. TP DOC GEN AI asks for related parties and connected persons as step two of the Local File wizard, with Excel import, before economic analysis is allowed to proceed.
That order is not a UI preference. It is how a defensible study is staffed. Characterise the deal. Then pick the tested party. Then pick the method. Then search. Reversing that order is how you end up with a TNMM on a financing arrangement.
A schedule that is specific enough to characterise is also specific enough to disclose. If you cannot name the contract, you are not ready for FAR. The wizard will let you type a vague line. A specialist on the walkthrough will not let it survive into the file you sign, because that line becomes the first exhibit.
Cross-border groups, languages, and consistency
International transactions often need the same economic story in more than one language. Local File translation covers English, Arabic, German, French, Italian, and Spanish. Numeric values are localised deterministically (German grouping, Arabic-Indic digits with UAE separators). A digit-integrity validator rejects any translated fragment whose digit sequence differs from the source. Statutory boilerplate ships only after professional legal review; Arabic legal text stays English until that review exists.
About thirty standard TP table headers per language come from a curated terminology catalogue. "Arm's length range," "Tested Party," and "PLI Selected" are translated by TP professionals, not by the model at runtime. If the English report is edited later, translations are badged Outdated with one-click re-translate. Entity legal names never flip.
That is how a Spanish Local File and an Arabic Local File stay the same study. Read the transactions article for a deal-level checklist, or the documentation page for the full Local File outline. To walk through a multi-entity schedule, book a demo.
Disclosure forms must match the transaction list
Form 3CEB and the UAE CT disclosure form are not "another Excel." They are the public statement of the same international transactions the Local File describes. Mismatch is an audit invitation. The 3CEB wizard and the UAE disclosure wizard live in the same product as the documentation generator for that reason.
Keep the transaction master clean, and the rest of TP compliance has a chance. Let it rot in a shared drive, and no amount of fluent industry overview will save the file.
Deemed international transactions, guarantees, and cost contribution arrangements are easy to omit because they do not look like invoices. If the FAR says a parent guarantees working-capital facilities, the schedule should say so, even if the GL never booked a fee. The same is true of secondments billed as "salary recharge."
Intangibles and financing belong in both the deal list and the Master File toggles. If the group licenses a trademark, the Local File for the licensee and the Master File intangibles chapter should describe the same licence. Inconsistency between those two artefacts is an audit gift. Capture the contract once, then generate both documents from that record.