About

Built by a practitioner, for practitioners.

TransferPricingLab exists because transfer pricing has been held hostage for too long by firms that bill six figures for work that, at its core, is a well-run checklist and a defensible comparables search.

01 — The story

Why this exists.

Transfer pricing is, at its best, a craft. A defensible study is a careful piece of analysis: a functional analysis that captures how a business actually works, a method selection grounded in OECD guidance and economic reality, a benchmarking search whose comparables can withstand scrutiny. At its worst, it's theater — a binder of dense paragraphs and unexamined comparables, billed at $300 an hour, that nobody reads until the tax authority asks a question.

I spent years inside firms that did both kinds of work. I watched senior practitioners redraft the same workpapers from scratch every engagement because the templates lived behind locked firewalls. I watched in-house tax teams pay Big Four rates for deliverables a competent practitioner could produce in a week. I watched mid-market multinationals quietly accept that "real" transfer pricing was something only $5,000-an-hour partners could deliver — when in fact most of the work is methodology, judgment, and patience, and none of those scale with hourly rates.

TransferPricingLab is the library and the practice I wished existed. Templates that work because they were built for real engagements, not for a marketing brochure. Advisory that's priced honestly and delivered by the person who scoped it. A resource for practitioners by a practitioner — without the theater.

02 — Principles

Five things we believe.

i.

Defensibility over performance

A binder that impresses in a board meeting but folds under audit is worse than no documentation at all. We optimize for what survives scrutiny, not what looks good in a slide.

ii.

Templates aren't substitutes for judgment

The hardest decisions in TP — method selection, comparable rejection, controversy positioning — require experience that no template can capture. We sell both: the templates that scale, and the judgment that doesn't.

iii.

Pricing should be transparent

The TP industry's pricing opacity is a service-quality problem. We publish prices, write fixed-fee scopes, and warn clients before scope creeps. The discipline forces us to be specific about what we're doing — which improves the work.

iv.

The practitioner does the work

The person you talk to in the intro call is the person doing the analysis, drafting the workpapers, and signing the deliverable. No staff partners, no warm handoffs, no offshore teams.

v.

Quality compounds; haste rarely does

A documentation pack done well in week six saves months of audit defense in year three. We take the time to do the work properly, because the alternative is more expensive in every dimension that matters.

03 — Methodology

How we approach the work.

Transfer pricing methodology isn't a secret. The OECD Guidelines, U.S. Reg. §1.482, and country-specific local file rules are public. The difference is in how the methodology is applied — the small judgment calls that compound across a study.

01.Functional analysis as foundation

Every study starts with how the business actually works — not how the org chart says it does. Interviews with operations, structured documentation, and a clear functions-assets-risks output that drives every downstream decision.

02.Method selection with reasoning

We document why we picked the chosen method — and why we rejected the others. The reasoning is part of the deliverable. This is the section auditors read first.

03.Benchmarking with explicit screens

Acceptance and rejection criteria are written before the search runs. Every comparable retained or rejected has documented reasoning. The interquartile range is the result, not the goal.

04.Documentation that reads

A local file is a document. It should be readable as one — clear narrative, logical flow, defensible structure. Not a 200-page dump of attachments held together by a cover sheet.

05.Defense-ready by default

Every deliverable is built assuming an auditor will read it. That standard is higher than "passes review" and lower than "wins every audit" — but it shifts the work in ways clients feel during controversy.

06.Updates as guidance evolves

The TP world doesn't stand still. OECD Pillar One/Two, Chapter X intercompany financing, BEPS 2.0 — guidance moves. Our templates and methodology update with it, and updates ship to past clients without a fee.

04 — Credentials

The résumé, briefly.

Experience [Personalize: e.g., "12+ years in transfer pricing across Big Four and in-house roles"]
Prior firms [Personalize: e.g., "Deloitte Transfer Pricing, in-house TP at [Company]"]
Education [Personalize: e.g., "MBA, [School] · BS Accounting, [School]"]
Credentials [Personalize: e.g., "CPA · CFA · Member, Tax Executives Institute"]
Industries [Personalize: e.g., "Technology, manufacturing, consumer goods, financial services"]
Speaking [Personalize: e.g., "TEI Annual Conference, Bloomberg Tax webinars, IFA chapters"]
Writing [Personalize: e.g., "Bloomberg Tax, Tax Notes, LinkedIn"]

05 — Two paths in

Browse the library, or book a call.

If you're solving a TP problem yourself, start with the templates. If you'd rather not, let's talk about whether an engagement is the right fit.

Browse the library → Book an intro call →