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
How to read a benchmarking study you didn’t write.
Most in-house tax teams accept benchmarking studies as black boxes — pages of comparables they don’t have time to scrutinize. This is a mistake. Here’s a framework for pressure-testing any study in under an hour, and the seven red flags that should make you push back.
02 — Recent
Latest writing.
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.
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.
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.
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.
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.
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.
Templates and
frameworks, ready to use.
View all products →
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.
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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.
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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.
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Benchmarking Study Workpaper
The structure around your database output — search strategy docs, acceptance/rejection matrix, comparability adjustments, and an interquartile range calculator.
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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.
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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.
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