Transfer Pricing Advisory
Intra-group pricing policy, full documentation and audit-ready defence. Built before the audit, not during it.
What this service is
Transfer pricing is where multinational groups quietly lose money. Either by undercharging an intra-group service and leaving margin in the wrong jurisdiction, or by overstating one and inviting an authority to reassess. Kaelo Advisory writes the policy, builds the documentation, and prepares the defence position so the group is reading from one consistent script everywhere it operates.
“Transfer pricing is the discipline where the cost of being wrong is paid years later, in audit, by the people who weren’t in the room when the policy was written.”
— An Operating Council principal, Kaelo Advisory
What we are accountable for
Where the work lands.
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01
TP policy design
A documented intra-group pricing policy across goods, services, royalties, and financing — reasoned, comparable-backed, defensible.
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02
Master file & local file documentation
Full BEPS-aligned documentation prepared annually. One canonical master file, jurisdiction-specific local files, no inconsistencies between them.
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03
Benchmarking studies
Comparables analysis run on accepted databases with a defended search methodology. Not a one-screen export.
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04
Audit defence preparation
The position a tax authority will see, the questions it will ask, and the written answers prepared in advance. Reviewed annually.
How we engage
From first email to standing review.
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01
Policy diagnostic
Three-to-four-week review of the current TP policy, master file, local files, benchmarking and audit-defence posture. Written gap analysis at the end.
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02
Policy rewrite or refresh, in writing
Where the diagnostic surfaces material gaps, we rewrite the policy and the supporting documentation. Where the policy is sound but stale, we run an annual refresh against the latest OECD updates.
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03
Audit-defence preparation in advance
The position a tax authority is most likely to challenge is identified before the audit cycle, with the written defence already on file. We do not wait for the letter.
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04
Standing annual engagement
Most TP work continues as a standing annual engagement — master file refreshed, benchmarking re-run, local files re-aligned. Fee documented; no automatic renewal.
Where this applies
The sectors this service is shaped for.
When to call us
The shape of the moment this work usually arrives in.
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01
You operate across multiple jurisdictions and your master file has not been refreshed in the last twelve months.
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02
You are receiving a tax authority enquiry about intra-group pricing and the existing defence position is incomplete.
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03
You are integrating an acquisition and need to align its TP policy with the group’s within the financial year.
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04
You are restructuring intra-group flows and need the TP architecture rewritten before the new flows go live.
Engagement profile
Annual TP policy refresh for a manufacturing group operating across five countries.
Master file rewritten, local files aligned, defence position updated before the regulator’s next cycle. The group’s tax team owns it; we sit on the standing engagement.
Recent mandate, anonymised
Defended an intra-group royalty position under regulator enquiry — closed without adjustment.
The written defence file was prepared two years before the enquiry. When the letter came, the response was on the shelf; the regulator closed the matter without proposing an adjustment.
For clarity
What we will not do here.
- We do not provide TP litigation representation. Where a dispute moves into adversarial proceedings, we work alongside engaged counsel.
- We do not use benchmarking databases whose methodology we cannot defend in writing. Some commercial datasets do not meet that bar.
- We do not bundle TP advice with tax-return filing — filings are a separate, locally licensed function.
- We do not market aggressive TP positions. Every policy we write is defensible against the audit cycle it will be tested against.
Frequently asked
The questions that arrive first.
- 01 Do you handle TP filings for our group?
- We do not file. We design the policy and prepare the documentation; filings are done by your locally licensed tax practitioners. Where Kaelo does not hold the licence, we recommend partners.
- 02 Which jurisdictions do you cover for TP work?
- The Kaelo footprint — UAE, India, Singapore, Seychelles, Bermuda — plus the major counterparty markets (EU, UK, China). Outside this footprint we work alongside locally appointed counsel.
- 03 How does BEPS Pillar Two affect TP policy?
- Pillar Two raised the floor on effective tax rates; TP policy choices that previously worked may now create unexpected GloBE income adjustments. The diagnostic phase checks the policy against the Pillar Two regime before recommending refresh.
- 04 Can you work alongside our existing tax advisor?
- Yes — second-opinion or specialist-overlay arrangements are common. We do not require exclusivity. Where we agree with the incumbent view, we say so in writing; where we disagree, we say that in writing too.
- 05 How long does a typical engagement run?
- Diagnostic: 3-4 weeks. Policy rewrite: 8-12 weeks. Standing annual engagement: year-on-year. Audit-defence support: scoped against the regulator’s timeline.
- 06 How does this connect to the other Tax & Structuring services?
- TP policy depends on holding-co architecture, interacts with the international tax structure, and sets the framing for indirect tax. The four work as one architecture.
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Written, considered replies within two working days. Initial conversations off-record, no fee, no commitment.
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