Transfer Pricing

Overview

What we deliver

We design intercompany pricing, prepare master and local files, and benchmark transactions so your policies hold up with the IRS, HMRC, CRA, and ATO.

Intercompany pricing is one of the most reviewed areas in any multinational. We help groups set arm’s length policies, prepare the documentation expected under the OECD framework, and align finance, tax, and operations on how value flows between entities. Our team handles functional analyses, comparable searches, and the master file, local file, and country-by-country reports required across the United States, United Kingdom, Canada, and Australia. We also support advance pricing agreements, year-end true-ups, and revenue authority queries. Policies are written in plain language and linked back to the underlying contracts, ledgers, and forecasts, so finance teams can apply them without guessing. Whether you are setting up your first intercompany flow or refreshing an aging study, we deliver documentation that stands on its own. Book a Call to review your current transfer pricing posture.

Fit Check

Built for teams like yours

Who it's for

Multinational groups with intercompany flows
US, UK, Canadian, and Australian parents
Inbound subsidiaries of overseas groups
PE-backed groups expanding internationally
Tech and IP-rich businesses with cross-border licensing

Pain points we solve

Outdated or missing TP documentation
Inconsistent intercompany invoicing
Weak benchmarking for service and royalty rates
Exposure during revenue authority reviews
Unclear ownership of TP within finance

What's included

Capabilities

Everything we cover in this engagement.

Functional and value chain analysis
Master file and local file preparation
Country-by-country reporting support
Benchmarking studies using commercial databases
Intercompany agreement drafting
Year-end true-up calculations
Advance pricing agreement support
TP policy training for finance teams

How we work

Our process

A clear, predictable path from kickoff to outcomes.

01

Scoping

We map entities, flows, and material intercompany transactions.

02

Functional analysis

We document functions, assets, and risks for each party to the transaction.

03

Benchmarking

We run comparable searches and select tested parties and pricing methods.

04

Documentation

We draft master file, local file, and supporting policies aligned to OECD guidance.

05

Roll-forward

We refresh studies annually and support any revenue authority queries.

What you get

Deliverables & outcomes

What you get

Master file and local files
Benchmarking study reports
Intercompany agreements
Year-end true-up workings
Country-by-country report
TP policy manual

Outcomes you can expect

Documentation ready before filing deadlines
Lower risk of TP adjustments
Consistent intercompany invoicing
Faster responses to authority queries
Clear ownership inside the finance team

Timeline

6 to 12 weeks per documentation cycle

Engagement

Monthly retainer, Project, Sprint

Tools we use

TP Catalyst, RoyaltyStat, Orbis, ONESOURCE Transfer Pricing, Excel

KPIs we track

Documentation coverage, benchmarking refresh cadence, query response time, true-up variance, audit adjustments

Client stories

What clients say

"

We had 14 cornerstone pages stuck on page two for 18 months. Their SEO crew rewrote the internal linking, cleaned up our schema, and shipped 22 supporting briefs over a quarter. Eight of those pages broke top three by month five. Organic pipeline went from a trickle to our second-largest source. Felt like watching interest compound.

James T.

"

Our old site was a Frankenstein of three previous agencies. We gave them a hard launch date tied to a trade show and they actually hit it. 47 templates, full product catalog migration, no broken redirects on go-live day. Our previous vendor missed the same deadline twice. This time my phone stayed quiet on launch morning.

Marcus L.

Proof