[Verse 1]
When companies trade across borders wide
With subsidiaries on every side
Section two-four-seven draws the line
Arms length principle by design
Independent parties at market rate
That's the standard we must calculate
[Chorus]
Two-four-seven keeps it fair and square
Arms length pricing everywhere
OECD guidelines show the way
Document today what you display
Transfer pricing rules we can't ignore
Keep it real like never before
[Verse 2]
Five methods help you find the price
Comparable uncontrolled is nice
Resale minus and cost-plus too
Profit split when deals are new
Transactional net margin's last
Choose the best that fits your past
[Chorus]
Two-four-seven keeps it fair and square
Arms length pricing everywhere
OECD guidelines show the way
Document today what you display
Transfer pricing rules we can't ignore
Keep it real like never before
[Bridge]
Contemporaneous papers tell the tale
Written when the deal sets sail
APAs can pave your road
Advance pricing breaks the code
But miss the mark and penalties bite
Twenty percent will dim your light
[Verse 3]
Master file and local file
Economic analysis with style
Functional risk and asset tests
Benchmarking beats all the rest
Revenue Canada wants to see
Your pricing methodology
[Chorus]
Two-four-seven keeps it fair and square
Arms length pricing everywhere
OECD guidelines show the way
Document today what you display
Transfer pricing rules we can't ignore
Keep it real like never before
[Outro]
When related parties make their deals
Arms length principle reveals
What independent firms would pay
Keep your transfer pricing straight