Every exposure, scored. Every change, caught.
PriceSmart is a per-exposure TP Risk Index: one cell for each transaction class you run, in each jurisdiction you run it, scored for audit scrutiny from public primary sources — every load-bearing claim cited. It tells you which exposures need attention, which benchmarks age out this year, and where the next study fee should go.
The pilot is paid — one cell, calibrated to your group — and the fee is credited against your subscription if you proceed.
Management fees × ~40 jurisdictions — the first cell — UK → Luxembourg management & advisory services fees — is built on this class. Walk through it on a call.
Illustrative — in a live cell, every value resolves to a statute section, case citation or authority publication.
Dozens of exposures. One hand-rolled Excel ledger.
A multinational’s transfer pricing lives in dozens of jurisdiction × transaction-class combinations at once, each with its own deadlines, thresholds and audit posture. The stakes are not abstract: large groups in TP disputes reported an average $56.3m in tax, $24.7m in penalties and interest, and $21.3m in legal fees (EY International Tax & TP Survey 2024), and 79% expect audit intensity to grow. The tools for staying ahead of it:
One-off studies
Published anchors run $10–30k per study, to $50–60k at Big4 scale — current fees are published nowhere. Each answers one question, once, then goes stale.
The Excel refresh ledger
Every Head of TP hand-rolls one: which cell was refreshed when, which benchmark ages out next. Only 25% of groups centrally manage TP compliance at all (EY 2024).
Regulatory trackers
“Germany changed a rule” — the same alert for everyone, and it stops there. No score, no per-class meaning, no comparable number.
Documentation platforms
A crowded, well-funded layer for producing files. None of them sell the layer above: which exposure needs attention this cycle.
Two verdict layers. Neither fence-sits.
Index layer — describes the regime
Every cell gets a scrutiny tier and a trajectory — Intensifying, Stable or Easing — built from public sources, with the scoring weights published. The index states facts about jurisdictions, never opinions on your position: a deliberate liability firewall.
Calibrated layer — lands on your own cells
The two middle verdicts are invalid without a named object: Monitor must name its trigger and date, Remediateits deficiency and deadline. Can’t name one? The engine is forced to Audit-Ready or Escalate. A cell covered by a bilateral APA is Audit-Ready by definition for the covered years.
Every report ends with “what would change this verdict” — falsifiable, not oracular.
Standing, not one-off.
Every cell carries its own ledger — law as at, benchmark vintage, refresh due — fed by a monitoring loop over statutes, circulars and case registries. The refresh ledger you keep in Excel today is the product.
Checkable, claim by claim.
Load-bearing claims resolve to a statute section, an OECD guideline paragraph, a case citation or an authority publication — from a source whitelist, rejected at generation time if they don’t resolve. Confidence badges are computed from that coverage, not asserted.
Honest about the boundary.
Where a jurisdiction publishes nothing, the tile says so. Where a conclusion needs your numbers, it sits in the “Positions requiring client data” box. Scarcity shown honestly is itself a data point.
From a cell name to a board-ready read.
Pick a cell
One transaction class in one jurisdiction — management fees in Luxembourg, royalties in Germany. ≈320 cells in the launch catalog.
Read the regime
Governing statute, thresholds, the three deadline dates, penalties, precedent, enforcement pulse — from public primary sources, cited.
Get the verdict
An Audit Scrutiny Score with published weights, a Low-to-High tier, and a trajectory. One comparable number across every jurisdiction.
Triage the portfolio
Rank every exposure you run, watch the refresh alerts, and point the next study fee where it earns its keep.
Five dimensions. Each with a public anchor.
A score you can’t decompose is a vibe. Every cell’s regime radar is built from named, computable anchors in the public record — and the weighting over the dimensions is published, so when your advisor asks where the 74 came from, you have the answer.
Audit Intensity
The one judgment-leaning dimension — badged as exactly that. Precedent counts never feed it: settlement-driven regimes resolve disputes invisibly, and absence of case law is not absence of enforcement.
Documentation Burden
Computed from thresholds, deadlines, language requirements and penalty-protection conditions — the statutory facts every defense file opens with.
Penalty Severity
From statutory penalty and interest regimes — the mechanics buyers most often misremember, as citable tables.
Dispute-Resolution Quality
From OECD MAP statistics — months to close, share resolved with full relief — plus the BEPS Action 14 peer reviews and arbitration access.
Legislative Volatility
A counted trailing series of substantive changes to the regime. Churn is measurable, so we count it rather than characterise it.
One slot recalibrates per transaction class — a loans cell watches what a royalties cell doesn’t. Same rubric, class-specific signal.
Where a jurisdiction publishes nothing for a metric, the tile says so — a coverage badge, never an estimate wearing a confident label.
One cell. Everything a defense file opens with.
Cell dashboard — risk verdict, thesis line, key risks, next steps — the one-glance answer to “do I need to open this one?”
Jurisdiction-class overview — governing statute and year, documentation thresholds, the three legally distinct deadlines, penalty headline, regime tier — plus landmark cases and the legislative pipeline.
Enforcement pulse — audit yield where the authority publishes it, MAP inventory and months-to-close, APA vital signs — each tile wearing a per-metric coverage badge.
Precedent cards — case name, citation, amount at stake, outcome, what failed — “quantum not disclosed” when it isn’t public, “thin precedent base” when it’s thin.
Thresholds & safe harbours — the published size-and-risk structure of the cell: materiality thresholds, de minimis rules, safe-harbour elections, authority-published risk zones.
Practical compliance profile — deadlines, language, statute of limitations, whether contemporaneous documentation conditions penalty protection — the page an advisor would photograph.
Exposure economics — penalty as a percentage of adjustment, statutory interest, protection conditions — citable mechanics, plus a calculator for your own inputs.
Illustrative layout — live values each resolve to their statute section [§].
The whole exposure map, scored and ranked.
One comparable number across every jurisdiction and transaction class — the ranking you use to allocate attention and budget, and the figure that goes in the board pack. The tier leads; the number is secondary, because nobody in a board pack cares about 74 versus 78.
EU27 + UK, CH, NO, US, CA, SG, HK, JP, AU + the fund centres
fees, royalties, loans, pooling, guarantees, CCAs, LRD, contract mfg
one class × one jurisdiction = one scored exposure
each with a published, computable public anchor
Cell Index
Every exposure on one comparable framework.
Illustrative data — jurisdictions and transaction classes are the real catalog; scores, tiers and trajectories are for demonstration only and don't reflect a live PriceSmart analysis.
Go deeper — without going soft.
Extend any cell with on-demand research on the four questions that decide a defensive posture — and every dive shows its own working, including the parts that need your numbers rather than ours.
Precedent
Case autopsies: what the taxpayer argued, why it failed, and what documentation would have defended it. The reading TP professionals learn defense from and never have time to do.
Enforcement actors
The authority’s current campaign focus, anchored to published instruments — compliance guidelines, taxpayer alerts, annual compliance plans. Whether your structure type is this year’s target.
Cell risk register
Probability × impact × horizon, early-warning signals, mitigation and contingency tripwires — in the format your enterprise-risk reporting already uses.
Remediation roadmap
The sequenced plan with owners — Head of TP, Group Tax, external advisor — that turns a risk read into something actually owned.
The published precedent base here is thin — and that scarcity is the finding, not a gap in the research. Luxembourg combines codified TP rules and active review with very little litigated case law, which is the signature of a settlement-driven regime: disputes resolve before they reach a published judgment, so the defensive lesson has to be read from the statutory conditions and the authority’s circulars rather than from case autopsies. Treating the quiet docket as evidence of a relaxed authority is the specific mistake this card exists to prevent.
- Whether the current mark-up sits inside the comparable range — requires your benchmarking study and the entity’s tested margin.
- Whether intercompany agreements match actual conduct — requires the executed agreements and the transaction ledger.
Illustrative — live dives cite and date every claim, and name what they cannot conclude without your numbers.
Fewer verified claims beat more invented ones — the discipline is enforced at generation time, not promised in a footnote.
Built to be checked by someone who checks for a living.
This buyer verifies sources professionally — so the product is designed around being audited, not around being believed. PriceSmart is pre-launch: there are no customers to quote and we won’t pretend otherwise. What there is, is a first built cell — UK → Luxembourg management fees — and a standard it has to pass.
Does any claim marked Grounded fail to check out?
The first acceptance question, put to a practising TP professional. Target: zero. Badges are computed from citation coverage, so a claim without whitelisted primary sources behind it cannot wear the Grounded label in the first place.
Can you tell, unaided, which parts need your client’s data?
The second. Target: yes, without being told. Conclusions that cannot be reached from public sources sit in an explicit “Positions requiring client data” box rather than being quietly inferred.
What happens where the record is thin?
The UK has usable published TP case law; Luxembourg has little. The cell says “thin precedent base” and explains why — a settlement-driven regime resolves disputes invisibly — rather than padding. Absence of case law is never displayed as absence of enforcement.
And where two runs disagree, that’s a bug, not a footnote. A consistency checker reconciles values across sections and between the main report and its deep dives before anything is exported — two generations of the same figure have to agree. Every load-bearing claim used in the design goes through a verification pass against primary sources before it reaches a client.
Your money flows are corridors. The index reads them that way.
A group’s intercompany flows aren’t dots on a map — they’re pairs: Luxembourg → UK, Ireland → Germany. The corridor view scores the pairs; the portfolio view ranks every cell you run on one comparable number.
Corridor heat-matrix
Counterparty jurisdictions × risk tier, and every corridor cell carries genuinely pair-specific data — treaty in force, arbitration coverage, withholding-tax interaction — not a counterparty score re-projected.
Portfolio triage
Every cell you run, ranked on one comparable scrutiny score, with refresh alerts on the benchmarks and rules that moved. The ranking that allocates attention — and the study budget.
39 jurisdictions. 8 transaction classes. One rubric.
Every combination is a cell, and every cell is scored on the identical rubric — which is what makes Luxembourg management fees and German royalties comparable numbers rather than two opinions.
EU27
27Including the fund domiciles Luxembourg, Ireland and the Netherlands.
- Austria
- Belgium
- Bulgaria
- Croatia
- Cyprus
- Czechia
- Denmark
- Estonia
- Finland
- France
- Germany
- Greece
- Hungary
- Ireland
- Italy
- Latvia
- Lithuania
- Luxembourg
- Malta
- Netherlands
- Poland
- Portugal
- Romania
- Slovakia
- Slovenia
- Spain
- Sweden
Wider Europe & North America
5The major audit programmes with published APA and MAP statistics.
- United Kingdom
- Switzerland
- Norway
- United States
- Canada
Asia-Pacific
4Including Australia, whose authority publishes per-arrangement risk zones.
- Singapore
- Hong Kong
- Japan
- Australia
Fund centres
3The domiciles the fund-administration world actually runs through.
- Jersey
- Guernsey
- Cayman Islands
Transaction classes
8One slot of the regime radar recalibrates per class — same rubric, class-specific signal.
- Management & service fees
- IP royalties & licensing
- Intercompany loans
- Cash pooling & treasury
- Guarantees
- Cost-contribution arrangements
- Limited-risk distribution margins
- Contract manufacturing
Need a jurisdiction we haven’t listed — or only the twelve you actually run? The catalog is a registry. Adding a jurisdiction, or narrowing the index to your group’s real footprint, is a configuration — not a rebuild.
One study buys one answer. The index stands over all of them.
This is not the study, cheaper— the filed deliverable legally can’t live in an index. It’s the layer above: for less than the price of one study a year, you know where the study budget should go. Study fee anchors: published 2017/2022 figures; current fees are published nowhere.
The people who own the exposure map.
Heads of TP & Group Tax
Portfolio triage on one comparable number, the refresh ledger off your desk, and the figure that goes in the board pack.
CFOs
Risk as money: citable penalty and interest mechanics per cell, and early warning before the audit letter — not after.
External advisors
Every load-bearing claim resolves to a primary source. The index routes questions to advisors sooner — it doesn’t replace them.
Fund administrators
White-label the index as your own risk-monitoring capability — one capability, delivered to hundreds of client structures.
An honest boundary: if you run one or two jurisdictions, an annual study genuinely suffices — this is built for groups carrying dozens of cells at once. And nothing here replaces filed documentation: licensed benchmarking ranges legally cannot live in an index, which is precisely why it can direct your study budget without competing with your advisors.
Start on one cell. Expand to the portfolio.
Pilot
one cell, calibrated to you
Where every engagement starts.
- One cell — your class, your jurisdiction
- Calibrated to your group’s parameters
- Walkthrough with the working shown
- Fee credited in full if you proceed
Index
all cells, monitored
The standing layer for the whole exposure map.
- The full cell catalog
- Scrutiny scores, tiers, trajectories
- Refresh ledger + change alerts
- Deep dives: precedent, enforcement, risk register
- Board-ready PDF export
Calibrated
your exposures, your verdicts
For groups that want verdicts on their own cells.
- Your parameters, per cell
- Audit-Ready / Monitor / Remediate / Escalate
- Portfolio verdict map
- Exposure economics on your numbers
- “What would change this verdict”, per cell
Fund administrators & corporate-services groups: the index white-labels to your client base — platform fee plus per-structure pricing. Talk to us.
The things buyers ask first.
Advisors are bought per engagement: a study answers one question, once, then goes stale. Nobody sells the standing layer — which of your exposures moved this quarter, which benchmarks age out this year, where the next study fee should go. We’re the instrument that tells you when to call the advisor, so the advisory budget gets better-spent, not cut.
No, by design. The index states facts about regimes — statutes, cases, published statistics — never opinions on your position. The calibrated layer is an internal risk-screening instrument whose text never enters a filing, and every report states explicitly what it is and is not. Even the verdict language is engineered for that boundary.
Five regime-radar dimensions, each anchored to public data — thresholds and deadlines, statutory penalty and interest regimes, OECD MAP statistics and the BEPS Action 14 peer reviews, a counted series of legislative changes — with the weighting published. Where a jurisdiction publishes nothing, the tile says so instead of estimating.
The filed deliverable depends on licensed comparables databases whose terms prohibit republishing, plus your own confidential numbers — a legal wall, not a technical one, and it protects this product too. On top of that wall: a source whitelist with claims rejected at generation time if they don’t resolve, confidence badges computed from citation coverage, and a standing refresh loop no one-off session can replicate.
Three engineered answers: badges are computed from citation coverage, so an unsupported claim can’t wear “Grounded”; every report names what would change its verdict, so it’s falsifiable rather than oracular; and nothing the product outputs is filed anywhere — your exposure to our errors is a prioritisation decision, not a tax position.
Trackers stop at “Germany changed a rule” — the same alert for everyone. The index scores what the change means, per transaction class, as one comparable number across the catalog; the calibrated tier lands it on your own exposure map. Alert → verdict → action; trackers stop at alert.
The launch catalog is ~40 jurisdictions (EU27 plus the UK, Switzerland, Norway, US, Canada, Singapore, Hong Kong, Japan, Australia, and the fund centres Jersey, Guernsey and Cayman) across 8 transaction classes — ≈320 cells. The catalog is a registry, not a rebuild: adding a jurisdiction, or narrowing to your footprint, is configuration.
A paid pilot: one cell — your transaction class, your jurisdiction — calibrated to your group, with the fee credited in full against a subscription if you proceed.
Prove it on one cell of your choosing.
Book a walkthrough of the first cell — UK → Luxembourg management fees — and follow any claim in it back to its source on the call. Or start a paid pilot: one cell, your transaction class, your jurisdiction, calibrated to your group, with the fee credited against a subscription if you proceed.