Created a draft with AI — but not sure if it’s correct?

What this is about

More companies are using AI to draft transfer pricing and other related materials. AI is fast, but it cannot assess whether the content reflects your actual operations or meets OECD and local tax requirements.

What we do

We review AI‑generated drafts, correct inconsistencies and ensure the document is clear, accurate and audit‑ready. You keep the speed of AI — without the risk.

When this helps

When you have an AI‑created draft and want to be confident that:

• the business description matches reality

• roles, risks and responsibilities are consistent

• pricing logic is properly justified

• OECD and local requirements are met

Send your AI draft for review

In an environment where business models evolve quickly and tax authorities apply increasing scrutiny, companies need transfer pricing and tax guidance that supports real‑time decision‑making, not only annual compliance. Our approach focuses on helping businesses navigate everyday operational choices with confidence, clarity, and full alignment with local and international tax requirements.

Practical, proactive and commercially grounded support

We provide practical, proactive and commercially grounded support that integrates seamlessly into your daily operations—whether you are pricing intercompany transactions, adjusting margins, evaluating new customer or supplier arrangements, or assessing the tax impact of supply‑chain changes. Our team ensures that decisions made today remain defensible tomorrow.

What we deliver

• Transfer pricing decision support for routine and strategic transactions (LRD and LRO pricing, management services, royalties, financing, cost allocations).

• Real‑time margin analysis and true‑up guidance, ensuring arm’s‑length outcomes throughout the year.

• Operational tax support linked to contracts, invoicing, and cross‑border transactions.

• Assessing the tax and TP effects of business changes, restructurings, new markets, or product launches.

• Price‑setting, benchmarking and documentation.

• Direct access for quick, business‑driven answers when questions arise.

Outcome

We help you make decisions that are not only commercially sound, but also fully compliant, well‑documented and defendable across jurisdictions. With our support, your finance, tax, and operational teams can focus on the business—while staying confident that transfer pricing and taxation are handled with precision.

Securing tax certainty before entering into a new arrangement or a business decision can significantly reduce risk and provide long‑term clarity. We help companies understand tax and transfer pricing implications upfront — before contracts are signed or operations change.

Proactive engagement with tax authorities

We support clients through advance rulings, pre‑transaction consultations, and informal discussions with tax authorities. The goal is to ensure that tax and transfer pricing outcomes are understood, accepted aligned with regulatory expectations from the outset.

What we deliver

• Preparation of ruling applications and supporting documentation

• Drafting explanatory memorandums and financial analyses

• Assessment of tax and TP implications of planned transactions or restructurings

• Representing in meetings and discussions with tax authorities

• Practical guidance to ensure proposed arrangements remain defensible across jurisdictions

Outcome

With our guidance, you gain confidence that your transfer pricing and tax positions are aligned with regulatory expectations—minimising disputes and improving predictability across jurisdictions.

Globally, scrutiny and audits are increasing in scope, frequency and sophistication. Our goal is to help clients manage audits efficiently, maintain control over the process, and achieve favourable outcomes with minimal disruption to the business.

End‑to‑end support throughout the audit cycle

We provide structured, evidence‑based support across all stages of a tax or transfer pricing audit — from initial strategy to final resolution. Our approach ensures that the economic rationale behind your arrangements is clearly presented, well‑supported and aligned with regulatory expectations.

What we deliver

• Audit strategy and planning

• Data preparation and analysis

• Responses to information requests

• Defence files and clarification memorandums

• Direct communication with tax authorities

• Representation in meetings and discussions

• Practical guidance to maintain consistency across jurisdictions

Outcome

We also work proactively to identify potential weaknesses and recommend corrective actions before issues escalate — helping you reduce uncertainty and strengthen your transfer pricing and tax position.

Transfer pricing documentation is more than a compliance requirement — it is a strategic asset that protects your business, supports tax certainty and ensures that your global operations reflect how value is truly created.

We help companies prepare clear, defensible and audit‑ready documentation that meets both OECD standards and local Finnish requirements, while remaining practical for day‑to‑day business use.

Clear, defensible and business‑aligned documentation

Our approach combines deep technical expertise with a strong understanding of your commercial reality. Whether you operate through a limited‑risk distributor, shared service centre, manufacturing entity, IP owner or financing hub, we translate your operating model into coherent, well‑structured documentation that stands up to scrutiny and audit.

What we deliver

• Master File and Local File preparation aligned with OECD Transfer Pricing Guidelines

• Entity‑specific FAR analyses with clear delineation of intra‑group transactions

• Benchmarking studies using robust methodologies (TNMM, CUP, Cost‑Plus, royalty analysis)

• Ensuring actual margins remain within arm’s‑length ranges

• Documentation for intra‑group agreements, including pricing logic and alignment with economic substance

• Support during tax audits, including responses to information requests and defence files

Outcome

We deliver documentation that is technically sound, compliant and aligned with your business reality — providing tax authorities with transparency while giving your organisation confidence and control over its transfer pricing position.

A well‑designed transfer pricing model should reflect how value is created in your business — today, not years ago. As organisations evolve, supply chains shift, margins fluctuate and tax rules tighten, existing models can easily drift away from economic reality.

Our transfer pricing model health check helps you assess whether your current framework is still robust, compliant and aligned with your commercial operations and value chain. We provide an independent, comprehensive evaluation of your pricing policies, functional profiles, financial outcomes and intercompany agreements.

What we assess

• Current TP model (LRD, LRO, commissionaire, service provider, manufacturer, IP owner, financing entity) against OECD guidelines and local practices

• Functions, assets and risks (FAR) to confirm that characterisation matches operational substance

• Financial performance relative to arm’s‑length ranges, benchmarking logic and peer‑group data

• Intercompany agreements for consistency, clarity and defensibility

• Year‑end results, true‑up needs and prospective price‑setting mechanisms

• Tax and operational risks, such as contract–conduct mismatches, persistent losses or over‑/under‑compensation

What we deliver

We identify mismatches between your business model and transfer pricing design, recommend corrective actions and highlight opportunities for simplification — including pricing mechanism improvements or a shift toward a more centralised model where appropriate.

Outcome

You receive a clear understanding of whether your transfer pricing still works — and what, if anything, should change. The result is a concise, actionable step plan that strengthens compliance, reduces audit exposure and ensures your transfer pricing supports, rather than constrains, day‑to‑day business decisions.

Business transformations — whether entering a new market, changing the supply chain, launching a new product or introducing new intra‑group services — require transfer pricing structures that are commercially viable and defensible from day one. Our support ensures that new transactions and models are designed with the right balance of tax compliance, operational simplicity and business relevance.

We work closely with finance, legal and operational teams to map the commercial drivers behind the planned arrangement, design the appropriate transfer pricing model and document the logic in a clear, audit‑ready manner.

What we deliver

• Design of transfer pricing models for new transactions, business expansions and restructurings

• LRD conversions, service model updates and commissionaire/agent model design

• IP licensing structures and financing arrangements aligned with value creation

• Mapping of commercial drivers and operational flows to ensure accurate characterisation

• Documentation of pricing logic, economic rationale and contractual alignment

• Practical implementation support to ensure the model works in day‑to‑day operations

Outcome

We help you structure transactions that accurately reflect where value is created — and that remain sustainable as your business grows. The result is a transfer pricing model that is commercially grounded, compliant and operationally simple to maintain.

When transfer pricing adjustments arise — whether in Finland or abroad — they can quickly lead to double taxation and significant financial exposure. We help companies navigate dispute‑resolution mechanisms efficiently, maintain control over the process and secure outcomes that restore tax certainty.

Structured support across all dispute‑resolution pathways

We assist clients through Mutual Agreement Procedures (MAP), EU Arbitration Convention processes and domestic appeals. Our support covers case preparation, coordination with competent authorities, economic analyses and negotiation strategy — ensuring your position is clearly presented and well‑supported.

What we deliver

• Preparation of MAP and arbitration submissions

• Coordination with competent authorities and tax administrations

• Economic analyses, defence files and explanatory memorandums

• Strategy for negotiations and dispute management

• Support in domestic appeals and interactions with local tax authorities

• Practical guidance to maintain consistency across jurisdictions

Outcome

We aim to secure timely and balanced outcomes that eliminate double taxation while preserving your broader tax certainty and business objectives. With our guidance, you gain a structured, controlled path to resolve cross‑border disputes with clarity and confidence.

We provide tailored training sessions, workshops and lectures that help finance, tax and operational teams understand and manage transfer pricing with confidence.

What we deliver

• Fundamentals of transfer pricing

• OECD guidelines and current developments

• Operational transfer pricing practices

• Transfer pricing documentation requirements

• Executive briefings and hands‑on team training

• Practical examples and case‑based learning tailored to your business model

Outcome

Your teams gain clear, practical understanding of transfer pricing concepts and how to apply them in day‑to‑day decision‑making — improving accuracy, confidence and alignment across the organisation.

When companies face transitions — such as rapid growth, restructuring, parental leave or resource gaps — we provide interim tax manager support to maintain continuity and expertise in tax and transfer pricing operations.

What we deliver

• Immediate support to manage daily tax obligations and compliance

• Oversight of transfer pricing processes and operational TP tasks

• Preparation of documentation, filings and audit responses

• Coordination across finance, legal and operational teams

• Hands‑on support in decision‑making, planning and risk assessments

• Seamless integration into your internal workflows and systems

Outcome

You gain a trusted, senior‑level resource who acts as part of your internal team — ensuring stability, timely execution and deep technical know‑how exactly when you need it most.