Tax authorities now scrutinize how transfer pricing is designed, not just how it's documented. Exactera pairs compliance-grade AI, proprietary data, and transfer pricing experts to design, support, and document defensible positions in every jurisdiction — from planning through audit.
Gain Support Across the Full Transfer Pricing Lifecycle
Defending your transfer pricing position means getting every phase right. Exactera works with your team end to end. The same data, AI, and experts carry forward, so your planning, your structures, and your documentation tell one consistent, defensible story.
Plan and Construct Defensible Positions
TP Planning & Optimization. Before documentation begins, we establish legally defensible intercompany pricing structures through functional analysis and benchmarking — so your policy is tax-efficient and built to defend from the outset.
Structure Complex Intercompany Transactions
- Cost Allocation. Document and defend intercompany service transactions, including stewardship analysis and the determination of key allocation drivers.
- Cash Pooling Analysis. Analyze short-term cash management arrangements, with benchmarking for withdrawal and deposit rates and administrative fees.
- Intercompany Financing Support. Specialized analysis for cross-border financing — credit rating assessments, debt-capacity modeling, guarantee fee benchmarking, interest rate benchmarking, and thin-capitalization reviews.
Document and Defend in Every Jurisdiction
Localized master and local files for every jurisdiction, generated in mandated formats and languages, with AI-verified benchmarks and built-in audit trails. Documentation is the proof of the planning that came before it — and it’s audit-ready from day one.
Compliance-Grade AI, Built for Transfer Pricing
AI-Benchmarking Engine Global Regulation Tracker Localized Documentation Secure, Centralized Records 
AI-Benchmarking Engine AI-Benchmarking Engine
Reliable comparable sets in minutes, comparing functional profile to functional profile to produce a defensible arm’s-length range
Global Regulation Tracker Global Regulation Tracker
Real-time tracking of local legislation changes, so master and local files stay compliant wherever you operate.
Localized Documentation Localized Documentation
Country-compliant reports in the formats and languages local authorities require.
Secure, Centralized Records Secure, Centralized Records
Every report organized and accessible to your global team, through staff changes and hybrid structures alike
Meet Our Transfer Pricing Experts
Every conclusion is reviewed by in-house specialists with experience from inside multinational corporations and at leading global advisory firms. We’ve sat on both sides of the table, and we’re accountable at every decision point that determines defensibility.
For intangible property, IP licensing, and intercompany financing, our analyses draw on RoyaltyStat — Exactera’s royalty rate and license-agreement database. For more than 25 years it has curated public SEC/EDGAR agreements into arm’s-length royalty and service-fee benchmarks trusted by tax, legal, and valuation professionals.
