The Practice
Expert execution, for your most complex engagements.
Some transfer pricing work is standard, which is why we created the Transfer Pricing Lab Products. The rest requires deep technical judgment. Partner with a specialist who combines Big 4 rigor with in-house pragmatism, while executing your strategy.
01 — How we practice
Three ways the practice differs.
i.
Fixed scope, fixed fee
Every engagement starts with a clear, written scope and a fixed fee. No estimated hours, no billing surprises. If the project scope shifts, we agree on it before a single change is made.
ii.
Direct practitioner access
The expert you speak with on the intro call is the exact person doing your work. Your deliverable is built and signed by a seasoned transfer pricing leader.
iii.
Defensible
Our deliverables are backed by years of proven experience, ensuring they hold up against strict tax authority review.
The work we take on.
Most common engagement
Transfer Pricing Documentation
Local file/transfer pricing documentation and master file preparation for multinationals. 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/transfer pricing documentation or to defend on a standalone basis.
- Search strategy memo
- Acceptance/rejection matrix
- Comparability adjustments
- Final benchmarking report with comparable search results
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 or any other tax authority is at the door
Audit Defense & Controversy
We provide comprehensive support for companies currently under audit or anticipating one. Our core services include IDR response support, penalty protection positioning, and APA/MAP preparation. Because every controversy is uniquely complex, we structure our defense engagements on an hourly basis.
- IDR response drafting and review
- Penalty protection documentation
- APA application support
- MAP/competent authority assistance
Ongoing partnership
Fractional TP Advisory
Ongoing transfer pricing oversight for growing multinationals that are not yet ready for a full-time, in-house hire. We offer a standing seat at your tax meetings, structured monthly check-ins, and on-call expertise, all while delivering top-tier strategic guidance.
- 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.
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Mid-market multinationals ($50M–$900M)
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.