Three tools that analyse an arrangement the way a practitioner would — then show you exactly how an examiner will challenge it.
Start with transfer pricingDescribe an intercompany arrangement. Get the practitioner's analysis and the auditor's challenge, side by side.
Open →Describe activities in a foreign country. See which PE threshold is in play and how an authority would argue it.
Open →Describe a holding or financing structure. See whether it reads as genuine substance or a conduit, and where it's exposed.
Open →An arrangement, a structure, or activities abroad — in a sentence or two.
The analysis you'd give, and the challenge it has to survive — reasoning over principles, not rate tables.
The likely line of attack and the open questions, so the position is built to withstand scrutiny.