Three ways to produce your transfer pricing documentation.
Multinational groups producing TP documentation across many entities, jurisdictions and years have three credible paths to get the work done. This page compares them — and sets out how we deliver the one we recommend.
How the work is actually done, how the team is shaped, what it costs in time and effort, and — importantly — what stays in your hands after the engagement ends.
The three approaches
The differences come down to who does the work, how it scales with volume, and what is left in your team's hands when the engagement ends.
Scorecard
Four dimensions, three approaches. Where the Software row shows a range, it reflects how much the score depends on which product you pick and how much you invest in implementation and ongoing upkeep.
| Dimension | The Pyramid | The Software | The Exoskeleton |
|---|---|---|---|
| QualityOf the final documentation | 1–5 ¹ | ||
| AffordabilityTotal cost over the engagement | 3–4 ¹ | ||
| SpeedFrom kickoff to delivered files | Once running ² | ||
| Ease for your teamHow hands-off the model is for you | 1–3 ¹ |
¹ Software scores vary widely depending on the product chosen, the business, and the amount of effort put into implementation and ongoing upkeep. The range shown reflects what is realistic across mid-sized in-house TP teams — with heavy investment the Software can reach the upper bound, without it, drift toward the lower.
² The Software speed score excludes the time to implement the tool, which is a separate up-front investment.
The Exoskeleton, in practice
How the workflow runs across a typical portfolio, how the agents are tailored to your group, and how ownership of the toolchain transfers to your team over time.
From input to delivered file — per entity-year
Inputs
Financial data, headcount, intercompany flows, CbCR, prior local files.
Anonymisation
Sensitive data is anonymised or removed before any AI processing.
AI draft
Agents produce the economic analysis and a complete local file in your preferred format.
Auto checks
Functional ↔ headcount, financial reconciliation, plus checks tailored to your group.
Senior review
A senior TP specialist reviews every output, owns the judgment calls, and signs off as the responsible advisor.
Delivery
Final file, audit-ready, with methodology and assumptions documented.
Tailored for your group — your context, not anyone else's
TP policies
Your group TP policy, intercompany agreements, and the methodology behind each pricing position.
Entity tree
Your legal entities, jurisdictions, regulated/unregulated status, and functional roles in the group.
Transaction map
Intercompany flows — services, financing, IP, support functions — by entity pair and year.
Master File & CbCR
Master File structure, CbCR data, prior-year local files, and benchmarking history.
Headcount & interviews
Detailed headcount data that informs the analysis, plus functional analysis interviews to fill the gaps.
Audit posture
Risk ranking by entity-year so high-priority files can be produced first or accelerated on request.
How ownership transfers
The exoskeleton is built to be handed over. Over the course of the engagement, your team takes on more of the work, and we step back to review, edge cases, and controversy.
We run the exoskeleton
We operate the agents end-to-end. Your team provides inputs, reviews milestones, and receives finished documentation. The backlog comes down; the workflow gets sharper with every file produced.
Co-pilot
Whoever you nominate starts operating the agents alongside us. We shift to review, edge cases, and policy work. The toolchain documentation gets formalised.
You wear the exoskeleton
Your team runs the workflow in-house, using a simple AI subscription (whatever is best-in-class at the time). We remain on call for review, refinements, and any controversy work. Human involvement keeps decreasing as the agents improve.
Let's talk about your documentation cycle.
A short note is usually enough to start. Tell us what you're working on — a backlog to clear, a fresh cycle to run, or a tax-authority question — and we'll come back with a clear next step, typically within a working day.