tp.alptransfer pricing at arm's lengthDoe & Roe LLC

Today And With tp.alp

Where the hours go now, and where they would go. The point is the team's time and the file's defensibility, not another tool.

TaskTodayWith tp.alp
Who owes a Local FileTotals rebuilt by hand from the ledger, the threshold from memory, the loan by its interest by mistake.Totals per category from the transactions, the published threshold cited, a loan by its maximum principal, exclusions (tonnage tax, interest-free payables) applied by rule.
BenchmarkingA spreadsheet rebuilt each year; accept/reject reasons in a column nobody reads; one quartile formula, unstated.Each company accepted or rejected with a reason and the sentence relied on; the range by three definitions; the tested party drawn against it; a change reopens the sign-offs.
AgreementsRead once, at signing. The 60-day payment term against the policy's 30 is found by the Tax Department.Each clause set against the policy and the file, mismatches flagged; agreements drafted from the policy, every clause sourced.
FinancingSafe harbour rates looked up, a bond yield copied from a website, the threshold checked against the interest.The circular applied: availability by principal, the borrower's yield fetched from the ECB, the shortfall in points and in euro.
ReviewEmails saying "looks fine", a PDF initialled, nothing tying the approval to what was approved.Reviewed, verified, confirmed, each with what was looked at, tied to the exact content; reopened by any change.
Next yearLast year's Word file copied and edited, hoping nothing moved.Roll-forward: what continued, what is new, what ended, which threshold was crossed, which sections need figures and which a rewrite.

How many hours each saves is not claimed here: it is what a pilot would measure.