Transfer pricing · Finding register
Transfer pricing,
with the evidence
to act.
Know which positions need attention, and why.
Begin with a focused diagnostic of the documents your team already holds.
Explore the worked example ↗01 / The question
Do the documents
support the same
position?
Agreements, policies and results can tell different stories. The useful question is where they differ, what the evidence supports and what your team needs to resolve.
Renlind is building an AI platform to connect your group’s transfer pricing position with the evidence behind it. The proposed diagnostic brings those questions into a finding register. Each interpretation stays beside its source, with the missing evidence and next action in view.
02 / The work, made visible
A finding you can
follow to its source.
This invented example shows the form of the work on a group wider than a pilot. The proposed pilot returns the same form of register for one financial year, two jurisdictions and up to three entities.
Illustrative worked example
High priorityNF-02
Inventory-risk descriptions differ
Source
1“The principal assumes the significant risks of the distribution business, including inventory risk. Local distributors act as limited risk distributors and are remunerated on a cost plus basis.”
Master file MF-2026, section 4.2, “Risk assumption”.
2“Title to the Products and all risk of loss, damage and obsolescence pass to the Distributor upon delivery to the Distributor’s warehouse. The Distributor shall bear the cost of any write-down of Products held in stock.”
Distribution agreements ICA-DIST-004 to 009, clause 7. Identical wording in all six.
Interpretation
The documents assign inventory risk differently
1,2 and the actual allocation remains unresolved. Neither passage shows who controls the risk or who could bear it.
Missing evidence
Decision records, inventory write-downs and evidence of who bears losses have not been supplied. The stock-holding instructions issued to the six distributors for 2024 to 2026 were also not in the set.
Review status
Not yet reviewed.
Open question
Who controls inventory decisions and bears losses in practice, and does that party have the financial capacity to bear them?
Next action
Obtain the decision and write-down records for 2024 to 2026 before either document is amended. The practitioner assesses conduct before recommending whether any document changes are needed. Proposed owner: group controller.
Reference: accurate delineation, OECD Transfer Pricing Guidelines Chapter I, section D.1; VML 31 §.
View in the full register ↗ Norrfors Industries Oyj, its documents and all figures are invented. Not tax advice.
03 / From documents to a decision
A clear sequence.
A practitioner at the review.
01Agree the scope
Choose the documents, jurisdictions and question to examine. Agree confidentiality and processing arrangements before documents move.
02Read and compare
AI-assisted analysis links differences and gaps to their sources. Unanswered questions and missing evidence remain visible.
03Review and act
A named practitioner reviews the register. Your team receives a source index, reviewed findings and proposed next actions.
04 / Begin with a bounded pilot
One focused read.
A useful next step.
A proposed diagnostic using existing documents. No ERP integration is required.
1financial year
2jurisdictions
3entities, at most
- Materials
- Up to 20 documents and 1,000 pages. Spreadsheet limits agreed separately.
- Your team
- Plan for 6 to 10 hours for scoping, questions and the closing meeting.
- Timing
- Target delivery: four weeks after complete intake and approvals.
- Terms
- Fixed fee, agreed in writing before documents move. Invoice after acceptance of the agreed source index, reviewed register and action plan.
Scope changes require agreement. Benchmarking studies, redrafting, filings, integration and ongoing monitoring are excluded.
Who carries the work
Expertise stays
in the conversation.
Renlind prepares the analysis from Finland. Before engagement, we name the responsible practitioner and contracting entity.
Your team supplies the business context. Your existing adviser can participate in the review.
