The tool prepares. People decide. The proof is kept.
tp.alp is a workbench for a transfer pricing practice. It reads the file, works out what each entity owes, benchmarks the prices, checks the agreements against the policy and assembles the Local File. Then it stops: nothing it produces is final until the team has reviewed it, a manager has verified it and a partner has confirmed it, each with the evidence saved.
A change to anything an item rests on reopens its sign-offs. Anything a model suggests counts for nothing until a person decides. Every threshold cites its source, and what could not be verified says so.
Choose a person under View As in the header to try each role. Walk Through Meridian Orchard All Engagements Check The Rules
▶ Watch The Film Show Me Around 75 seconds, with subtitles; or a few steps across the pages, one thing at a time.
Start Where You Sit
No sign-in on this demonstration: choose who you are. Each person signs and writes only on their own engagements.
The Groups
Every group, entity, figure and comparable is invented, and Doe & Roe LLC is a fictitious firm. Each group is built around points a practitioner would test.
- Meridian Orchard GroupLocal Files and benchmarking for the Cyprus entities of a juice and preserves group with a German distributor and a Greek producer.
- Northbridge Marine HoldingsShipping group under tonnage tax: ship management between tonnage tax companies, crewing under income tax, an interest-free shareholder balance and a physical cash pool.
- Helios Lane SoftwareSoftware group with a Cyprus development centre on contract R&D, and a Cyprus IP company that owns the platform but controls none of its development.
- Cobalt Bay ResortsHotel group: a €20m bank loan guaranteed for no fee, a brand licence, and senior management services under the €1,000,000 threshold that still cannot use the 5% safe harbour.
- Pinewood Street PharmaPharma distributor: a limited-risk distributor making a loss, a loan inside the safe harbour threshold, and a loan to a director.
- Aegean Crest ShippingA Marshall Islands shipping group run from Limassol, under tonnage tax, that has never done any transfer pricing: four tax years to catch up, a chartering desk under income tax, and loans between tonnage tax owners.
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How It Works · Today And With tp.alp · Where AI Helps · Questions · Running It For Real · The Rules · Market Data · Glossary