Resources

Field notes from the practice.

Methodology breakdowns, audit defense playbooks, and frank takes on transfer pricing — written for practitioners, not for marketing departments.

Browse by topic —

01.

Documentation

7 ARTICLES

02.

Benchmarking

7 ARTICLES

03.

Methods & methodology

6 ARTICLES

04.

Financial transactions

6 ARTICLES

05.

Controversy & defense

6 ARTICLES

06.

Industry & strategy

6 ARTICLES

01 — Featured

02 — Recent

Latest writing.







02

The functional analysis your auditor actually wants to see

Most functional analyses are written for the client, not for the auditor. The result: pages of marketing language and zero defensible analysis. Here’s the structure that holds up.

03

Why mid-market multinationals are stuck with Big Four pricing

The structural reasons mid-market companies overpay for TP — and the three changes in the market that are starting to break the pattern.

04

Choosing between TNMM and CUP: a decision framework

Method selection drives the whole study. Here’s how to make the call without spending three days reading the OECD Guidelines for the fifth time.

05

What to do in the first 72 hours after a TP audit notice

The early hours of a controversy engagement set the tone for the next 18 months. The four moves that protect your position — and the three that quietly weaken it.

06

Comparable rejection: the case for being more aggressive

Most studies err toward keeping comparables to look defensible. The opposite approach — aggressive rejection with documented reasoning — is often the stronger position.

07

OECD Chapter X: what changed for intercompany financing

The 2020 Chapter X guidance is now the de facto standard. Here’s how it actually plays in practice — and where the guidance still leaves uncomfortable gaps.

02 — The library

Templates and

frameworks, ready to use.

View all products  →

— 01
Most popular

Intercompany Agreement Template Pack

Eight model intercompany agreements — management services, cost-sharing, distribution, IP licensing, intragroup financing, and more — with annotated guidance on every clause.

 

$199
Details →
— 04
Methodology

Method Selection Framework

A decision guide — PDF and Excel scoring tool — for choosing between CUP, Resale Price, Cost Plus, TNMM, and Profit Split with worked examples across common scenarios.

$99
Details
— 02
Foundational

The Local File Template

A structured Word template following OECD BEPS Action 13 Annex II — placeholder sections, example language, and embedded guidance for every requirement.

$499
Details →
— 05
Advanced

Benchmarking Study Workpaper

The structure around your database output — search strategy docs, acceptance/rejection matrix, comparability adjustments, and an interquartile range calculator.

$249
Details
— 03
Workbench essential

Functional Analysis Workbook

The functions-assets-risks analysis that makes or breaks a TP study. Structured interview template, scoring matrix, and an output summary ready for your local file.

$199
Details →
— 06
Flagship

The TP Documentation Playbook

One hundred pages walking through the full documentation lifecycle, with every template in the library bundled in. Our most comprehensive product.

$499
Details

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