OECD 2022 Guidelines · BEPS Action 13

The AI Transfer Pricing
Associate that defends every conclusion.

Four specialist agents — Consultant, Reviewer, Tax Auditor, Arbitrator — produce benchmarking studies audit-ready for Big4 review, tax authorities, and your CFO. Nothing leaves the platform without a human signature.

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

Multi-agent architecture

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

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

TP Consultant
Big4 Manager

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

TP Reviewer
Big4 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 signed 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

Reviewer overrides, adds, removes. Approves. Customer downloads PDF & Excel.

Built to be defended.

Every output must be explainable to tax authorities, external auditors, Big4 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

Run your first study this week.

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

Create your account