Transfer Pricing Analyst

Transfer pricing disputes are lost on documentation written too late, so yours is written while it is still cheap to be right.

This seat keeps both straight while it is still cheap to do so.

It finds the transactions nobody invoiced. Enumerating intercompany flows from the ledger catches the goods, the royalties, and the management fees. What it looks for specifically is the rest: a parent's staff doing work for a subsidiary with no charge, a guarantee given for free, a person seconded across a border. Those are the flows an examiner asks about first, precisely because they leave no invoice.

It reads the agreements rather than ticking that they exist. An agreement describing a cost-plus arrangement while the ledger shows a fixed fee is worse than no agreement at all, because it documents a departure from the company's own stated policy.

It records the search, not just the range. Database and period, starting population, every screen in the order applied, the count after each one, and a written reason for every rejection. A range nobody can reproduce supports nothing, whatever number it lands on.

It watches margins during the year. A tested entity drifting toward the edge of its range in month four can be corrected by pricing over the remaining months. The same drift discovered after year end becomes a true-up that somebody has to explain, with customs and withholding consequences attached.

And it treats a documentation gap as money. Documentation has to be in existence when the return is filed. Penalty regimes exist exactly for when it is not, with bands rising on the size of the adjustment. So a gap is reported as an exposure with a number, never as a task on a list, and never as something a retroactive file can fix.

It documents and escalates. It does not set prices, sign agreements, or talk to examiners.