OECD 2022 Guidelines · BEPS Action 13

The AI Transfer Pricing
Associate that supports every conclusion with a traceable evidence trail

Four specialist agents — Consultant, Reviewer, Tax Auditor, Arbitrator — produce benchmarking studies audit-ready for Big Four review, tax authorities, and your CFO. Nothing leaves the platform without approval from a qualified human reviewer.

Method & oversight

Not one model. A panel that argues until the position is defensible

No single model decides anything. Four specialist agents challenge every position, the reasoning trail is stored end to end, and nothing ships without sign-off from a human transfer pricing reviewer — OECD-aligned at every step.

Every recommendation is challenged, attacked, then arbitrated. The reasoning trail is stored alongside the report — ready for any future audit.

TP Consultant
Big Four Manager

Analyses the transaction, identifies tested party, recommends method & PLI.

TP Reviewer
Big Four Director

Challenges the recommendation, surfaces alternative methods, demands more analysis.

Tax Authority Auditor
Tax Inspector

Attacks assumptions the way HMRC, AEAT, and BZSt would. Flags audit risk.

Arbitration Agent
Independent Partner

Weighs all three voices and issues the final defensible position with confidence score.

From related-party transaction to reviewed and approved benchmarking study

1. Transaction intake

Two entities, transaction type, functions, risks, assets. NACE / NAICS optional.

2. Multi-agent analysis

Method selection, tested party, PLI. Every alternative considered and rejected with reasoning.

3. OECD screening

13 mandatory filters applied to the universe. Every removal logged with justification.

4. Human review & deliver

The reviewer can override decisions, add or remove comparables, and approve the final set. Customer downloads PDF & Excel.

The economics

Days, not weeks — at a fraction of the cost

Because a defensible arm's-length range shouldn't take weeks of manual work or an outsized budget.

Days, not weeks

A full benchmarking study is ready for human review in days — not the weeks a manual Orbis workflow takes.

A fraction of the cost

Priced at a fraction of a manual benchmark — no database seats, no junior hours burned on screening.

Defensible by design

Every conclusion carries an evidence trail and human review, so the arm's-length range stands up to tax authorities and auditors.

Built to be defended

Every output must be explainable to tax authorities, external auditors, Big Four reviewers, corporate tax teams, and the CFO. We store the full chain of reasoning — including what was rejected and why.

  • TP consultancies replacing manual Orbis workflows
  • Tax advisory firms scaling without scaling headcount
  • Corporate tax departments owning the file in-house
  • CFOs needing a defensible position before quarter-end
  • Family offices and international groups

Live evidence

A real range, straight from public filings

A real arm's-length range computed by the platform from public filings — 26 comparable companies out of a universe of 310. Deterministic maths, not model guesses.

TNMM · operating margin · n=26 · universe 310 · FY2023–2025 filings

Min
-11.6%
Q1
4.1%
Median
10.3%
Q3
22.0%
Max
48.9%

Snapshot from the Playground estimate, 20 July 2026 · GB + FR · NACE 62.01 · services.

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comparables seeded
0
OECD screening filters
0
specialist AI agents
0%
human-reviewed deliverables

Getting started

Run your first study this week

Free pilot for one related-party transaction. No commitment.

01
Try the Playground

See a live arm's-length range for your scenario in two minutes — free, anonymous, no signup.

Open the Playground
02
Run a pilot study

Create an account and run a free pilot on one related-party transaction — no commitment.

Create account
03
Book a team demo

Walk your tax team through the platform in a guided session.

Book a demo