About
Built by a practitioner, for practitioners.
Transfer Pricing Lab equips corporate tax teams and advisors with audit-ready documentation, reliable benchmarking, and strategic advisory support they can stand behind. Expect rigorous methodology, practitioner judgment, and pricing that reflects the work.
Why this exists.
Transfer pricing is, at its core, a precise craft. A defensible study is a careful piece of analysis: a functional analysis that captures how a business actually operates, a method selection grounded in OECD guidance and economic reality, and a benchmarking search built to withstand rigorous regulatory scrutiny.
Throughout my career navigating complex transfer pricing environments within and alongside multinational corporate tax teams, I saw the need for a more efficient, transparent approach. Too often, growing organizations and independent advisors struggle to find partners who deliver strategic, defensible value without unnecessary complexity or bloated internal processes.
Transfer Pricing Lab is the resource and practice I built to bridge that gap. We provide meticulously structured documentation, reliable benchmarking, and hands-on advisory services driven by practitioner judgment and rigorous methodology. It is built to deliver exceptional quality and audit-ready results, directly to the professionals who need it.
Whether stepping in to provide fractional oversight for a growing multinational, or delivering discrete benchmarking workpapers for an independent advisor, the goal remains the same: clarity, defensibility, and uncompromising quality. True transfer pricing excellence relies on sound methodology, seasoned judgment, and extreme attention to detail. Transfer Pricing Lab scales those exact elements to your current stage and specific needs.
02 — Principles
Five things it we believe.
i.
Defensibility over performance
Documentation that impresses in a boardroom but fails under audit is a liability. We optimize exclusively for what will survive rigorous tax authority scrutiny, prioritizing robust defense over mere optics.
ii.
Templates aren’t substitutes for judgment
The most critical decisions in transfer pricing-method selection, comparable rejection, and controversy positioning-require frontline experience that no static document can replicate. We provide the scalable tools to streamline the process, backed by the expert practitioner judgment required to execute it flawlessly.
iii.
Pricing should be transparent
Transparent pricing drives better outcomes. By offering published prices, clear fixed-fee scopes, and proactive communication, we ensure absolute clarity on every deliverable. This discipline forces precision in our scoping, which directly improves the quality and focus of our work.
iv.
The practitioner does the work
The advisor you consult with on day one is the exact practitioner conducting the analysis, drafting the workpapers, and signing the final deliverable. We believe in direct partnership, ensuring that strategic nuance is never lost in translation between scoping and execution.
v.
Quality compounds; haste rarely does
Thorough, proactive documentation today saves months of costly audit defense down the line. We invest the time to execute properly from the start, recognizing that foundational quality is the most effective risk mitigation strategy a corporate tax team can deploy.
How we approach the work.
Transfer pricing regulations are public knowledge—the OECD Guidelines, U.S. Treas. Reg. §1.482, and local country rules are accessible to everyone. The true differentiator is application. It is the nuanced, expert judgment calls compounding across a study that transform raw data into a highly defensible position.
01.Functional analysis as foundation
Every study begins by capturing how the business actually operates, going beyond surface-level organizational charts. Through targeted operational interviews and structured documentation, we develop a precise functions, assets, and risks (FAR) profile that anchors every downstream decision.
02.Method selection with reasoning
We clearly articulate not only why a specific method was selected, but critically, why alternatives were rejected. This rigorous rationale is integrated directly into the deliverable, anticipating the exact questions tax authorities prioritize.
03.Benchmarking with disciplined screening
Objective acceptance and rejection criteria are established before the search ever begins. Every comparable retained or discarded includes documented reasoning. The interquartile range is the natural outcome of a rigorous process, never a predetermined goal.
04.Documentation that reads cohesively
A local file should function as a clear, readable narrative. We prioritize logical flow and defensible structure, delivering a highly organized, cohesive document rather than a disjointed collection of attachments.
05.Defense-ready by default
Every deliverable is constructed with the assumption that an auditor will scrutinize it. This elevated standard goes far beyond merely passing internal review—it fundamentally shapes the work to proactively protect our clients during controversy and audit scenarios.
06.Adaptive to evolving guidance
The global transfer pricing landscape is highly dynamic. As frameworks like OECD Pillar One/Two, Chapter X intercompany financing, and BEPS 2.0 evolve, our methodologies adapt immediately. Our templates update in tandem with regulatory shifts, and critical updates are provided to past clients without additional fees.
The résumé briefly
Tosin Akande is a corporate tax and transfer pricing professional with extensive experience managing and defending global tax strategies. Having navigated complex transfer pricing landscapes across multiple international jurisdictions, Tosin has driven tax strategy at leading multinational organizations, including EY, Citi, and Orthofix.
- Experience
17+ years in transfer pricing across Big Four and in-house roles
- Prior firms
EY (Ernst & Young) Transfer Pricing, Citi, Orthofix, and various Fortune 500 companies
- Education
Bachelors’ and Masters’ in Economics
- Credentials
Documentation, Planning, Restructuring, and IP Valuation
- Industries
Oil & Gas, Energy, Technology, Consumer Goods, Automotive, Medical Device, Airline, and Financial Services
- Speaking
ITR Global Transfer Pricing Forum
- Writing
Bloomberg Tax, Tax Notes, LinkedIn
05 — Two paths in
Browse the library, or book a call.
If you are solving a transfer pricing problem internally, start with our audit-ready templates. If you need fractional support or a dedicated advisory partner, let’s discuss how an engagement fits your needs.