A transfer pricing engagement moves through 5 steps, from the conflict check to testimony. Each step ends in something counsel can review, and the typical timeline shows how long each phase runs.
Engagement process
Retention and conflict check: We confirm conflicts across the group's affiliates and the opposing parties, identify the transactions, years, and forum at issue, establish the retainer, and agree on the report deadline and any disclosure dates.
Records and data request: We request the intercompany agreements and amendments, the transfer pricing documentation for each year, legal-entity and segmented financial statements, general ledger detail of the intercompany accounts, the related tax filings, and the operating records and interviews the functional analysis needs.
Analysis and modeling: We delineate the controlled transactions, perform the functional analysis, evaluate the methods under the best method rule, search for and screen the comparables, compute the arm's length range, and quantify any adjustment or restated profit, with the effect of each contested choice shown.
Draft report and counsel review: We deliver a draft that states every transaction, assumption, screen, and adjustment, with the rejected methods and comparables explained, and review it with counsel for completeness and factual accuracy before finalizing.
Final report and testimony support: We issue the final report in the form the forum requires and provide deposition and trial testimony, critique of the opposing transfer pricing analysis, and updated calculations as the record develops.