The Practice
When you need it done, not just templated.
Some transfer pricing work is template-able. Some isn’t. For engagements that need judgment, you work directly with the practitioner doing the work — no pyramid of juniors, no scope creep, no surprise invoices.
01 — How we practice
Three ways the practice differs.
i.
Fixed scope, fixed fee
Every engagement starts with a written scope and a fixed fee. No hourly billing surprises. If the scope changes, we say so before we change anything.
ii.
Direct practitioner access
The person you talk to in the intro call is the person doing the work. No staff partners, no offshore teams, no warm handoffs. The deliverable is signed by the person who built it.
iii.
Defensible, not theatrical
We build deliverables that survive an audit. Not deliverables that impress in a board meeting. The two often look different — and we’ve made our choice.
The work we take on.
Most common engagement
TP Documentation
Local file and master file preparation for multinationals with $50M–$500M in revenue. OECD-aligned, audit-ready, delivered in four to six weeks from kickoff.
- Functional analysis interviews and write-up
- Local file (per OECD Annex II structure)
- Master file (per OECD Annex I structure)
- Defense memo for novel positions
Standalone or bundled
Benchmarking Studies
Defensible comparables searches using industry-standard databases. Full workpapers and reports, ready to drop into your local file or to defend on a standalone basis.
- Search strategy memo
- Acceptance/rejection matrix
- Comparability adjustments
- Final benchmarking report with IQR
Specialized expertise
Intercompany Financial Transactions
Intercompany loans, guarantees, and cash pooling priced against OECD Chapter X. The hardest TP transaction type, with the highest tax authority scrutiny.
- Credit rating proxy analysis
- Interest rate determination memo
- Guarantee fee analysis (if applicable)
- Model loan agreement drafting
When the IRS or HMRC is at the door
Audit Defense & Controversy
IDR response support, penalty protection positioning, and APA/MAP preparation. For companies under audit or anticipating one — engaged hourly because no two controversy engagements are the same.
- IDR response drafting and review
- Penalty protection documentation
- APA application support
- MAP/competent authority assistance
Ongoing partnership
Fractional TP Advisory
Ongoing TP oversight for growing multinationals not ready for a full-time hire. A standing seat at your tax meetings, monthly check-ins, and on-call expertise without the Big Four invoice.
- Standing monthly tax-team meeting
- Ongoing TP policy review
- Transaction-by-transaction guidance
- Annual documentation refresh
03 — How an engagement runs
Four phases. No surprises.
i.
Intro call
30 minutes, no charge. We discuss what you need, who’s involved, and whether the engagement is the right fit. No pitch deck.
ii.
Scope & fee
Within 48 hours, you receive a written scope and fixed fee. Sign and we begin. No retainer if scope is straightforward.
iii.
The work
We do the work. Weekly status notes, mid-engagement draft for review, no surprises. You see everything before final delivery.
Delivery & defense
Final deliverable, walkthrough call, and standing offer to defend our work for free if your auditor or tax authority asks questions.
The companies we do our best work for.
-
Mid-market multinationals ($50M–$500M)
Past the startup stage, not yet at the Big Four threshold. The sweet spot for our pricing and our depth.
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Boutique tax and law firms
Firms that occasionally need TP expertise but don’t have a dedicated TP partner. We work behind the scenes; you keep the client relationship.
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In-house tax teams of 1–3
Lean tax teams at growing multinationals who need a TP-specialist partner without hiring one full-time.
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PE-backed portfolio companies
Companies preparing for a tax-due-diligence event, an IPO, or a structural reorganization that triggers TP requirements.
05 — Start here
Let’s see if we’re the right fit.
30 minutes, no charge, no pitch. We talk about what you need and whether we can help. If we can’t, we’ll tell you who can.