Your TP policy. Documented.
Defensible. Done.

The main reason customers switch is cost and speed — $50K and six months for documentation that Commenda delivers in four weeks at a fraction of the price. The second reason is that Commenda’s documentation doesn’t live in a PDF on a shared drive. It’s a live platform: always current, always accessible, integrated with your entity and corporate tax compliance. If you want to retain your Big Four firm for complex advisory questions, do that — Commenda handles the systematic documentation and filing work that should never have been billed at advisory rates.

Commenda uses the same commercial databases as Big Four firms — Bureau van Dijk, Orbis, Royalty Range — to identify comparable uncontrolled transactions. The methodology is documented, the search criteria are reproducible, and the arm's length ranges are established using standard interquartile analysis. The difference is that Commenda systematizes the process rather than doing it manually from scratch each time, which is why we can deliver faster. The output — documented comparable search, arm's length range, tested-party positioning — is the same.

Your team provides the source data — entity structure, intercompany transactions, financials — and reviews the deliverables. Commenda's TP experts handle the policy drafting, benchmarking analysis, documentation preparation, and filing. For most engagements, your team's involvement is a kickoff call, a data handoff, and a review-and-approve step on each Master File and Local File. For complex positions (new transaction types, restructurings, audit defence), our experts brief you before finalising.

Commenda produces OECD BEPS Action 13-aligned documentation (Master File, Local Files, CbCR) applicable in all 140+ countries that have adopted the OECD framework. For Local Files requiring jurisdiction-specific formatting or local-language filings, Commenda’s expert network covers all major jurisdictions including the US, UK, EU member states, Australia, Singapore, Canada, India, and more. Tell us your entity footprint on the first call and we’ll confirm coverage upfront.

Week one is the intercompany structure mapping — we identify every related-party transaction across your entity group, categorize them by type, and assess which require documentation. Most companies discover transactions they hadn’t formally considered TP-relevant (management fees, cost recharges, intercompany loans) in this process. From there, we draft the policy, run the benchmarking, and build the documentation package. If you’ve never had documentation before, we’ll also assess whether you have any prior-year exposure that should be addressed.

Tightly. Intercompany transactions flagged through your ERP integration flow directly into the TP module for documentation alignment. Your TP policy is consistent with your corporate tax positions by design — not by hoping your TP advisor and your tax accountant talked to each other. When your entity structure changes (new subsidiary, new jurisdiction), Commenda’s entity management module flags the TP implications automatically. This is the integration that customers running separate TP advisors never have.

Yes, but context matters. If you have existing documentation, Commenda can review it for gaps and help you prepare a defence position. If you don't have documentation, we can produce a contemporaneous package on an accelerated timeline — which is better than going into an audit with nothing. Tell us about the audit when you book a call and we'll give you an honest assessment of what's achievable and on what timeline.