Business overview
A description of the business, including the organizational structure, industry conditions, and economic and legal factors affecting pricing.
The most rigorous §1.6662-6 documentation package a mid-market MNE can commission.
Transfer Pricing Documentation Engine assembles a penalty-protective documentation package — every principal document, every required search, the economist-signed conclusion, and the 30-day response calendar — checked against the letter of IRC §6662(e) and Treas. Reg. §1.6662-6 before a qualified economist releases it.
Every principal document of §1.6662-6(d)(2)(iii)(B)Economist-signed arm's-length conclusionComparable-company screening & interquartile rangeSpecialist release on every package2-week standard SLA
Why packages fail
A single missing document can forfeit penalty protection.
A mid-market MNE's transfer pricing documentation is only as strong as the package behind it. Miss one of the ten principal documents, skip a required functional analysis, misapply the interquartile range, or fail to document the tested-party selection — and the IRS can impose a 20–40% valuation-misstatement penalty under §6662(e).
Most companies rely on Big 4 firms that charge $25k–$75k+ per entity and take eight weeks, or they file with thin documentation and carry naked penalty exposure. The statute has not been read end-to-end since the last engagement. That is exactly where completeness gaps hide.
Transfer Pricing Documentation Engine exists to close that gap with a single, exhaustive standard applied identically to every file.
1 of 10
missing principal documents is enough to jeopardize penalty protection
The benchmark
Measured against the letter of the regulation — subsection by subsection.
We do not summarize the law and hope. Every package is scored against a versioned rule pack tied to the exact text of Treas. Reg. §1.6662-6. These are the provisions each package is held to.
Functional analysis
A detailed functional analysis of the controlled transactions, identifying the functions performed, assets used, and risks assumed by each party.
Method selection & comparability
Documentation of the transfer pricing method selected, the reasons for selection, and the comparability analysis including comparable companies.
Economic analysis & arm's-length conclusion
The economic analysis, including the interquartile range, and the conclusion that the controlled transactions are at arm's length.
Controlled transactions list
A list of all controlled transactions, including the dollar amounts and the nature of the transactions.
Financial data & segment P&Ls
Financial data and segment profit-and-loss statements used in the analysis, reconciled to the tax return.
How a package is built
Intake to economist release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A qualified economist signs every release. That order is never reversed.
01
Gap Scan
Upload the financials, intercompany agreements, and org chart. We return a free completeness read: which principal documents and analyses you already have, and which are missing.
02
Data extraction & segment P&L
As your authorized clerical agent, we extract financial data, build segment P&Ls, and corroborate against the trial balance.
03
Grounded drafting
The business overview, functional analysis, and industry narrative are drafted from your validated data and the §1.6662-6 rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
All ten principal documents are checked; the interquartile range is verified; the comparable-company set is screened; any failure blocks release.
05
Economist review & sign-off
A qualified transfer pricing economist reviews the method selection, comparable acceptance, and arm's-length conclusion, and signs the package.
06
Delivery
You receive the package: Local File, Master File (if required), benchmarking study, evidence log, and the 30-day response calendar — ready for your tax director to file.
The bar we hold
Rigor you can measure.
100%
Economist-signed
No package ships without a qualified economist's signature.
2 weeks
Standard SLA
From complete intake to released package.
<1%
Critical-defect target
Tracked against a gold-standard package library.
10
Principal documents
Every §1.6662-6(d)(2)(iii)(B) document, every applicable file.
Why Transfer Pricing Documentation Engine
Built to be the most thorough option a mid-market MNE has.
Penalty-protective, by design
The deliverable is penalty protection itself — every principal document and analysis accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run searches as your clerical agent. We never give legal advice, and a qualified economist owns the judgment calls.
Engagement
Flat fee, per released package. No hourly billing, ever.
Simple, predictable, and aligned with a documentation standard — not a cut of any tax savings.
- A free Gap Scan before you commit — see exactly what is missing.
- One flat fee per released Documentation Package; disclosed pass-through database fees.
- Optional fixed-fee attorney review for complex structures or litigation exposure.
- Optional Annual Refresh Add-on for the next year's update at a reduced fee.
FAQ
Questions, answered precisely.
Is Transfer Pricing Documentation Engine a law firm?
No. Transfer Pricing Documentation Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-exposure matters.
Do you give tax advice or represent us before the IRS?
No. We prepare documentation as your clerical agent. The economist's conclusion is an economic opinion, not legal advice. Your tax advisor retains responsibility for filing positions and IRS representation.
What makes a package 'complete'?
Completeness is defined by the regulation: all ten §1.6662-6(d)(2)(iii)(B) principal documents present, the functional analysis and comparability analysis verified, the interquartile range computed, and the arm's-length conclusion signed. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is two weeks from complete intake to an economist-released package. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released package, plus disclosed pass-through database costs. No hourly billing and no percentage of any tax savings or penalty avoided.
See what's missing before it costs you penalty protection.
Start with a free Gap Scan. Send your financials, intercompany agreements, and org chart and we'll return a completeness read against every subsection of §1.6662-6.
Documentation-completeness service · not legal advice · your tax advisor files every return.