Agents, crafted for you.
Practice Management
Draft client proposals, project roadmaps, and fee estimates.
Generate engagement letters, work-plan decks, and kickoff materials.
TP Research
Research transfer pricing laws, regulations, and guidances.
Access and analyse transfer pricing case law and rulings.
Reporting
Prepare OECD-compliant Master File and Local File documentation.
Generate TP disclosure forms, return schedules, and tax slips.
Produce XML Country-by-Country Reports and run risk analytics.
Assess nexus and Amount A reallocation under OECD Pillar One rules.
Compute GloBE ETR and top-up tax for Pillar Two compliance.
Design and generate jurisdiction-specific documentation.
Prepare the annual APA compliance package with authorities.
Data
Store and harmonise all transfer pricing data for the preparation and defence of group compliance.
Economic Analysis
Prepare, assess, and document functional analyses.
Allocate profits using the profit split method.
Benchmark profits using the TNMM/CPM method.
Benchmark prices using the CUP method.
Benchmark mark-ups using the Cost Plus method.
Benchmark margins using the Resale Price method.
Allocate direct and indirect costs across entities.
Benchmark service fees.
Value intangibles using cost, market, or income-based approaches and calculate royalties.
Prepare robust industry analyses.
Price intra-group debt using comparability-adjusted bonds and loans.
Analyse convertibles, mezzanine capital, and other hybrid financing arrangements.
Apply the hedge fund model for trading and asset management operations.
Benchmark financial and performance guarantee fees.
Benchmark factoring contracts.
Benchmark leasing arrangements.
Benchmark captive insurance premiums.
Determine synthetic credit ratings for group entities.
Prepare debt capacity analyses for group entities.
Calculate weighted average cost of capital for group entities.
Price cost sharing / cost contribution arrangements.
Price fees and rates for notional and physical cash pooling arrangements.
Prepare a value chain analysis.
Legal
Draft intra-group agreements.
OTP
Set up an operational transfer pricing systems aligning policies with results.
Generate invoices for intra-group transactions.
Policy & Risk
Draft transfer pricing policies and conduct policy planning.
Assess the risk of transfer pricing adjustments.
Draft post-merger risk and planning memoranda.
Gain insights from Country-by-Country Reporting risk analytics.
Draft M&A due diligence memoranda.
Examine profit attribution to permanent establishments.
Assess valuation for transfer pricing and customs.
Audit
Prepare for and navigate transfer pricing audits.