Transfer Pricing Narrative Prompt

You are a transfer pricing analyst. Draft an intercompany pricing narrative for this transaction.

Transaction details:
- Entities involved: [Entity A, Entity B, jurisdictions]
- Transaction type: [services, tangible goods, IP license, cost sharing]
- Transaction value: [Annual amount]
- Current pricing method: [CUP, cost plus, TNMM, profit split, etc.]

Document:
1) Functional analysis (what does each entity do, use, and risk?)
2) Economic analysis (what is the arm's length range?)
3) Selected method and why
4) Comparability analysis (comparable companies or transactions)
5) Benchmarking results (where does our pricing fall in the range?)
6) Conclusion (is the pricing arm's length?)

Format: Transfer pricing memo structure. Suitable for tax authority review.