Global Snapshot
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Years
Cumulative partner-level transfer pricing experience across global advisory environments.
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Clients
Select CPA and advisory firm clients supported across global regions.
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TP projects
Transfer pricing engagements delivered across jurisdictions in the last 10 months.
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Member team
Dedicated transfer pricing professionals with strong international tax and transfer pricing exposure.
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ADIT
ADIT-qualified transfer pricing specialists anchoring technical quality and review.
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Databases
Access to leading global TP databases for robust benchmarking and analysis.
Who We Serve
ARN Advisors serves CPA, accounting, consulting and legal firms worldwide as a dedicated Transfer Pricing Centre of Excellence. We strengthen your TP delivery capability with scale and precision
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Our Collaboration Mode
• Seamless white-labeled delivery
• Partner-led reviews and quality control
• Standardized frameworks for consistency
• Confidential and secure handling of all client information
• Scalable support for peak seasons
• Multi-country transfer pricing experience
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Global Delivery Strength
We serve multinational engagements across the US, Europe, Middle East and Asia, bringing strong cross-border regulatory insight and practical experience to every assignment.
Our Transfer Pricing Capability
Complete Transfer Pricing Support for CPA Firms Worldwide
Our services cover the full transfer pricing lifecycle and can be delivered under a completely white-labeled model.
Strategic Guidance and Policy Advisory
We support advisory firms by building the strategic foundation of transfer pricing for their clients. This involves defining how related party transactions are structured, priced, and governed across jurisdictions to ensure practical and defensible policies that align commercial reality with regulatory expectations. We begin by analysing the group’s existing transfer pricing position and policies to assess defensibility and audit readiness, and to identify areas where improvements or realignment may be required.
- Transfer pricing impact and position analysis
- Review of existing policies and transaction structures
- Assessment of defensibility and audit readiness
- Recommendations for policy and structural improvements
- Global and regional transfer pricing policy design
Benchmarking and Economic Analysis
We deliver robust economic and benchmarking analysis that supports consistent and defensible transfer pricing outcomes. Our work focuses on ensuring that margins and pricing are supported by reliable data and appropriate methods. The analysis is built to remain relevant across years and to support documentation, advisory requirements, and audit defence.
- Functional, asset, and risk analysis
- Selection of the most appropriate transfer pricing method
- Arm’s length range and margin computation
- Comparable searches using global databases
- Periodic benchmarking updates and refresh
Documentation and Compliance Support
We manage the preparation and maintenance of transfer pricing documentation with a strong emphasis on quality, consistency, and regulatory alignment. Documentation is treated as a structured and repeatable process, ensuring it reflects the actual business model, economic analysis, and policy positions adopted by the group.
- Local File and Master File preparation
- Country specific documentation support
- Contemporaneous documentation alignment
- SOP and documentation governance support
- Coordination with financial and tax teams
APA and Dispute Resolution Support
We support clients through audits, assessments, and dispute resolution by preparing structured technical explanations and defence documentation. Our focus is on clearly articulating transfer pricing positions and ensuring consistency in responses across jurisdictions, supported by robust analysis and documentation.
- Unilateral and bilateral APA support
- Assistance during assessments and audits
- Preparation of defence documentation
- Litigation and appellate support materials
- Transfer pricing risk mitigation strategy support
These capabilities together cover the full transfer pricing lifecycle, from initial position assessment and policy design to documentation, compliance, and dispute support.
These capabilities are delivered as an integrated transfer pricing function, either as your complete TP team or as a confidential backend capability supporting your advisory practice. Together, these cover the full transfer pricing lifecycle, from initial position assessment and policy design to documentation, compliance, and dispute support.
Our Transfer Pricing Capability
Our services cover the full transfer pricing lifecycle and can be delivered under a completely white-labeled model.
Strategic Guidance and Policy Advisory
These cases are perfectly simple and easy to distinguish.
- Related Party transaction guidance
- Global TP policy design
- Cross-border transaction structuring
- Pricing policy documentation and SOP development
- Jurisdictional studies and risk assessment
Benchmarking and Economic Analysis
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- FAR analysis
- Selection of the Most Appropriate Method
- Arm’s length range computation
- Comparable set building using global databases
Documentation and Compliance Support
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- Master File and Local File preparation
- CbCR support
- Contemporaneous documentation
- SOP and governance development
- Deputation and extended workflow support
APA and Dispute Resolution Support
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- Unilateral and bilateral APA support
- Representation during assessments
- Litigation and appeal support
- TP risk mitigation and negotiation strategy
Dedicated Team
Professional Individuals
Co-Founder, ARN Advisors
CA, Exec MBA (IIT Mumbai), ADIT
15+ years of experience in Transfer Pricing and International Tax. Specializes in advisory, dispute resolution, APAs, MAPs and compliance for multinational groups.
Co-Founder, ARN Advisors
BE, MSc (RMIT), Exec MBA (IIT Bombay), Senior Management MBA (IIM Ahmedabad)
20+ years of experience across technology, AI and business strategy. Leads delivery excellence, systems and workflow optimization.
Partner, ARN Advisors
Chartered Accountant
12+ years of experience in transfer pricing and international taxation, including BEPS compliance, documentation, APAs and audit support across industries.
Why CPA Firms Partner With ARN
Why Advisory Firms Work With Us
CPA and Advisory firms face increasing pressure to deliver high-quality transfer pricing work while managing cost, timelines, and risk. Many advisory firms prefer to retain control while exploring efficient ways to manage transfer pricing delivery. As workload and complexity increase, oversight takes time and capacity becomes harder to manage.
We help simplify this by taking ownership of the transfer pricing execution process, allowing firms to focus on client relationships and advisory outcomes.
What We Do
We provide end-to-end transfer pricing support covering strategy, analysis, documentation, and defence. Our work is structured, repeatable, and built to withstand regulatory scrutiny.
From reviewing the existing transfer pricing position to delivering defensible documentation and audit support, we ensure consistency and clarity across the full transfer pricing lifecycle.
How We Make Transfer Pricing Easier
Less operational burden
We reduce the time and effort required to manage transfer pricing work by running a disciplined and well-defined delivery process.
Strong control and consistency
Every engagement follows clear review protocols and quality standards, ensuring reliable outcomes across years and jurisdictions.
Predictable economics
Our fixed and standardised pricing approach removes uncertainty and makes collaboration easier for advisory firms.
How We Work With Firms
Advisory firms engage with us in different ways, depending on how they want to structure and manage their transfer pricing delivery. Our approach is flexible, structured, and designed to integrate seamlessly with existing teams and processes.
Some firms rely on us as their complete transfer pricing team, while others use us as a backend capability supporting an established practice. In both cases, the focus remains the same: strong control, consistent quality, and predictable economics.
Our collaboration is built around clear ownership, defined processes, and disciplined execution, allowing firms to scale transfer pricing delivery without adding internal complexity.
Designed to fit the way advisory firms already work.
Our Engagement models
Advisory firms work with us in different ways, depending on how they want to structure and manage transfer pricing delivery. Our engagement models are designed to provide flexibility while maintaining strong control, consistent quality, and clear accountability.
Some firms rely on us as their complete transfer pricing function, while others engage us as a backend capability supporting an established practice. In each case, the objective remains the same: to make transfer pricing delivery easier to manage, more predictable in cost, and dependable in outcome.
Our models are structured to integrate seamlessly with existing teams and processes, allowing firms to scale transfer pricing work without adding operational complexity.
Designed to fit the way advisory firms already work.
Engagement Model 1
Outsourced Transfer Pricing Function (TP Team-in-a-Box)
What it is
We take end-to-end ownership of your transfer pricing function, operating as your dedicated offshore TP team rather than a resource pool. Our team assumes responsibility for execution, quality, and delivery under a single, integrated capability model.
How it works
• We function as your firm’s internal TP team for defined geographies or client segments
• End-to-end responsibility for TP analysis, benchmarking, and documentation
• Senior-led delivery with built-in review and quality control
• Seamless coordination with your partners and client-facing teams
What this replaces
• Building and managing an in-house TP team
• Multiple freelancers or fragmented vendors
• Rising fixed costs and onshore capacity constraints
Best suited for
• CPA and advisory firms without an internal TP practice
• Firms looking to launch or scale TP services efficiently
• Partners who want ownership, accountability, and control—without building from scratch
Designed to fit the way advisory firms already work.
Engagement Model 2
White-Label Backend Transfer Pricing Capability
What it is
We function as a confidential, white-label transfer pricing capability center supporting your firm’s backend execution while you remain fully client-facing.
How it works
• End-to-end TP execution: analysis, benchmarking, and documentation
• Senior-led delivery with strict confidentiality and data controls
• Flexible engagement structures aligned to your volume and complexity
• Your brand, your client relationship, we stay invisible
Best suited for
• Established CPA and TP firms seeking cost-efficient backend delivery
• Firms looking to improve realization without expanding onshore teams
• Partners who value quality, control, and discretion
Both engagement models are designed to give advisory firms flexibility in how they structure transfer pricing delivery, while maintaining strong control, consistent quality, and clear accountability
Designed to fit the way advisory firms already work.
Dedicated Team
Professional Individuals
Our power of choice is untrammelled and when nothing prevents being able to do what we like best every pleasure.
Director
Amelia Margaret
Team Leader
Andrew Cameron
Manager
Sofia Charlotte
Incredibly
Effective Case Studies
Recruiting
Shared Time Human Resources Management
Human Resources
Essential Steps to Writing Job Description
Customers Experience
Insights
Aparna delivered robust documentation, including Local File preparation, and conducted thorough benchmarking analyses across the full transfer pricing lifecycle. This included planning, documentation, and audit defence support. Their detail-oriented and highly practical approach added significant value and ensured consistency, accuracy, and defensibility in our transfer pricing positions.