Transfer pricing health check
Find out what a tax authority would challenge — before they do.
A fixed-scope review of your intercompany pricing, documentation and audit exposure, grounded in the OECD Transfer Pricing Guidelines. You get a written risk memo naming the specific positions that would not survive a challenge, ranked by what they could cost you.
Reply within one business day · Fixed fee agreed before work starts · Confidential
What the health check covers
Documentation health
Master file, local files and CbCR consistency against the OECD three-tier standard. We flag what a tax authority would ask for first and what is missing or stale.
Method selection
Whether CUP, resale price, cost plus, TNMM or profit split is the right and defensible choice for each transaction — and whether your file justifies it.
Comparables defensibility
Search strategy, rejection reasons, comparability adjustments and interquartile positioning. The rejection matrix is what usually fails under challenge.
DEMPE and intangibles
Whether legal ownership matches the functions performed, risks controlled and funding provided — the single most common source of post-BEPS adjustments.
Intercompany financing
Loan pricing, credit rating derivation, cash pooling, guarantees and thin-capitalisation exposure under Chapter X.
Penalty and adjustment exposure
A quantified view of the adjustment range and penalty protection status per jurisdiction, so you know what you are actually carrying.
Who this is for
- In-house tax teams
- You need a second pair of eyes before the file goes out, or an independent read on a position you have inherited.
- CFOs and finance leaders
- You want the exposure quantified in numbers you can put in front of a board or an auditor, not in tax language.
- Advisors and counsel
- You need specialist transfer pricing capacity on a live controversy or a restructuring without adding headcount.
What you get
- A written risk memo covering each material intercompany transaction
- A red-flag register ranked by adjustment likelihood and size
- Method and comparables review with specific defensibility gaps named
- A prioritised remediation plan with effort estimates
- A 60-minute walkthrough call with the reviewer
Typical turnaround is two to three weeks from receiving your documents. Live controversy with a running deadline is prioritised.
Signals you need this now
- You have received an audit notice, an information request or a questionnaire.
- An IP or principal entity holds returns but has few or no people behind it.
- Documentation has not been refreshed since a restructuring or an acquisition.
- Routine entities are recording losses, or margins swing year to year.
- Intercompany loans, guarantees or cash pooling were priced without a rating analysis.
- You crossed the €750m CbCR threshold and are now visible in ways you were not before.
Request your TP Health Check
Tell us what is prompting the review. A specialist replies within one business day with a proposed scope, the documents needed, and a fixed fee.
Frequently asked
- What does a TP Health Check cost?
- It is fixed-fee and scoped after the first call. The fee depends on the number of jurisdictions and material transactions, not on hours. You get the number before any work starts.
- How quickly can you start?
- We reply to every request within one business day. A scoped review typically starts within a week, and we prioritise live controversy where a statutory deadline is running.
- Is what I share confidential?
- Yes. The details you submit are used only to scope your review. Nothing is added to a marketing list or shared outside the review team.
- What should I have ready?
- Whatever exists: the latest local files and master file, intercompany agreements, a transaction inventory, segmented P&Ls, and any correspondence from a tax authority. Missing documents are themselves a finding, so do not delay the call to assemble them.
- Which jurisdictions do you cover?
- The review is grounded in the OECD Transfer Pricing Guidelines, which most jurisdictions follow, with local-law overlays for the countries in your footprint. Tell us the jurisdictions in the form and we confirm coverage before you commit.
- Which languages do your consultants work in?
- English, Russian, Ukrainian, Lithuanian, Spanish, Italian, Greek, Hindi, Mandarin Chinese and Arabic. Pick your preferred language in the form and we match you with a consultant who works in it.
