For transfer pricing teams, in-house and advisory

Transfer pricing documentation that remembers what you decided, and why.

Fynto drafts each year's report from fresh evidence, then stops and asks wherever the draft contradicts last year's position. Your team's calls are kept, with the reasoning, and never silently rolled forward.

Works with the benchmark study or database you already have. Runs in your cloud account or on your hardware.

Acme Group · FY2025 · Functional analysis 1 of 3 open
Drift gate. This year's draft contradicts a position your team set last year.
Acme Services GmbH · IT support services
Characterization of the tested entity
Last year · FY2024
Limited-risk service provider
Set by J. Rivera · 14 Mar 2025
“Routine support under a cost-plus agreement. No development of the platform.”
This year's draft · FY2025
Entrepreneur
From the FY2025 service agreement amendment and headcount file: Acme now employs the platform engineering team and directs its roadmap.
The draft does not decide. You do.
Confirm the change Revert to last year Leave open
Whatever you choose is recorded with your name, the date, and your reason. The report cannot be finalized while this is open.

Two ways to draft next year's report.
Both lose the judgment.

A transfer pricing file is rewritten every year about mostly the same entities and transactions. The report records the conclusion. It does not record the alternatives your team considered, or why they chose this one. When the person who made the call moves on, the reasoning goes with them.

Regenerate from scratch

The new draft reflects this year's evidence. It also quietly changes a characterization or a method, and nobody notices until someone happens to compare it against last year's file. Usually that someone is an examiner.

Roll last year forward

Last year's positions carry into this year's report. A position that stopped being true in March is still in the file in December, because nothing prompted anyone to revisit it. The error compounds exactly when staff turn over.

Fynto does both, and keeps them apart

Every year's draft is written from that year's evidence. Separately, Fynto keeps a record of every call your team made last year, with the reasoning. Where the draft and the record disagree, the draft stops and asks. Where they agree, last year's call is offered back as one click, and the click is recorded. Last year's position is brought back as a question when the draft disagrees, an offer when it doesn't. Never as an answer.

Three moves,
every cycle.

This is what a reviewer sees when they open a file. Nothing is decided that they did not click.

1

Draft from this year's evidence

Upload the agreements, financials, and organization charts for the year. Fynto proposes the controlled transactions, the functional profile of each entity, the characterization, and the method, each one pointing at the document it came from.

The draft does not look at last year's file. That independence is what makes the comparison in the next step mean something.

Acme Group · FY2025 · Controlled transactions Drafted from 14 documents
IT support services · Acme Services GmbH → Acme Inc.
Proposed: intra-group services, cost of services plus · from Services Agreement 2025.pdf, p. 4
Review
Platform license · Acme Inc. → Acme Services GmbH
Proposed: license of intangibles, royalty · from IP License Amendment.pdf, p. 2
Review
Working capital loan · Acme Inc. → Acme Services GmbH
Proposed: financing, interest · from Loan Note Mar 2025.pdf, p. 1
Review
Acme Group · FY2025 · Method selection Blocked · 1 gate
Drift gate. The draft proposes a different method than last year.
IT support services · Acme Services GmbH
Last year · FY2024
Cost of services plus method
J. Rivera: “Routine services, reliable cost base, no comparable uncontrolled price available.”
This year's draft · FY2025
Profit split method
Follows from the entrepreneur characterization proposed in the functional analysis: both parties now make non-routine contributions, so neither is a routine tested party.
Confirm the change Revert to last year Leave open
2

Where it contradicts last year, it stops

A real change in position becomes a gate that blocks the report. The gate shows last year's position, who set it, and the reason they gave. The reviewer confirms the change, reverts to last year, or leaves it open with a note.

No model sits between the reviewer's click and what gets recorded. Each gate is one decision. There is no “confirm all.”

3

Where it agrees, last year's call is one click away

When the draft and the record agree, last year's value and reasoning sit under the current one with a Reuse button. The reviewer takes it or doesn't. Either way, the choice is written down with their name on it.

Items left open last year come back first. “Leave open” never turns into “forgotten.”

Acme Group · FY2025 · Benchmarking · accept / reject 31 candidates
Northwind Managed Services Inc.
This year: undecided
Reuse FY2024 call
FY2024 · Rejected by P. Okafor: “Owns and licenses proprietary software; not functionally comparable to a routine service provider.”
Contoso Technical Support LLC
This year: undecided
Reuse FY2024 call
FY2024 · Accepted by P. Okafor: “Independent, routine IT support, three years of data.”
Every accept and reject is one recorded decision. Reuse is a click, never a default.

Try it

A drift gate,
in your hands.

Make the call a reviewer would make. Then see what Fynto writes down, and what the next reviewer sees a year later.

Acme Group · FY2025 · Functional analysis Blocked · 1 gate
Drift gate. This year's draft contradicts a position set last year.
Acme Services GmbH · IT support services
Characterization of the tested entity
Last year · FY2024
Limited-risk service provider
Set by J. Rivera · 14 Mar 2025
“Routine support under a cost-plus agreement. No development of the platform.”
This year's draft · FY2025
Entrepreneur
From the FY2025 service agreement amendment and headcount file: Acme now employs the platform engineering team and directs its roadmap.
You are the reviewer. What do you do?

Illustrative data. Nothing you type here leaves your browser.

Four kinds of judgment,
kept across cycles.

Each one is recorded the moment a reviewer makes it, with their name, the date, the reason, and the alternative they turned down.

Transaction treatment

How each controlled transaction was characterized: a service, a license, a loan, a sale. And why the draft's proposal was accepted or overruled.

Method selection

Which pricing method applies to each transaction, which ones were rejected, and the facts the choice rested on.

Functional characterization

Each entity's functions, assets, and risks, the characterization that followed, and the narrative the reviewer wrote or edited about it.

Comparable accept / reject

Every candidate company in the benchmarking study, whether it was accepted or rejected, and the reason. A rejected comparable comes back next year with its reason attached.

Start with last year's report, not a blank file

Upload the prior-year report you already have, whether your team wrote it or your advisor delivered it. Fynto reads its transactions, functional analysis, and conclusions into this year's file as proposals for your team to review. Each confirmation becomes the first entry in the record. The drift gates start working in your second cycle, and the reasoning is captured from the first.

New file · import prior report
.pdf Acme Group TP Documentation FY2024.pdf
Controlled transactions found11
Entities with a functional profile4
Sections mapped to this year's file9 of 10
Kept aside for reference1
Everything found is a proposal. Nothing is confirmed until a reviewer confirms it.

Curious how the record is built? Read the engineering post →

Bring your own benchmark.
Fynto finishes the report.

Keep the comparables database you already license and the screening approach you already trust. Export the search, or hand over the accept/reject matrix your team already worked. If your advisor delivers the benchmarking study, ask for the accept/reject workbook behind it and upload that. Fynto records every accept and reject, computes the arm's-length range, and carries the result through method selection into the report.

Uploaded comparables stay in your workspace. The range is computed from your rows, never quoted from a PDF.

Acme Group · FY2025 · Benchmarking · import Rights attested
What you can hand over
.xlsx
Raw search export
Fynto runs the screens. A screen it could not run is marked “never ran,” not assumed.
.xlsx
Worked accept/reject matrix
Your team's decisions adopted as-is, reasons kept, gaps left open for review.
.xlsx
Price schedule (CUP)
Comparable prices go straight to the range.
Arm's-length range · interquartile Tested party operating margin 8.2% · within range
25th 75th

Three years later,
an examiner asks why.

The report says what the position was. It rarely says what else was considered, what the evidence looked like at the time, or who made the call. By the time the question arrives, that person may have left the company.

With Fynto, every position in the file has a record behind it. Re-decisions do not overwrite earlier ones. They sit on top, in order, so the full history of a position is there to hand over.

For each position, you can show
The position taken
And the alternative the draft proposed, if it proposed a different one.
Who decided, and when
A named reviewer and a timestamp on every decision, including reuse of a prior call.
The reason given
In the reviewer's words, written at the time, not reconstructed under pressure.
The evidence on screen
Which documents the reviewer was looking at, and which page the draft pointed to.
Every change since
Each re-decision points at the one it replaced. Nothing is deleted.
What was left open
Open items are disclosed in the file and carried into the next cycle, not dropped.

Built with the teams
who sign the file.

Fynto is a San Francisco company. We are onboarding a small number of design partners: in-house tax teams and advisory firms that sign off on transfer pricing files every cycle and want the reasoning behind each position to outlast the people who wrote it, and the advisor who drafted it.

What a design partnership looks like

  • 01Start with one file: last year's report, this year's documents, and your benchmark export or your advisor's accept/reject workbook.
  • 02Your reviewers work the file in Fynto. Every gate they hit and every reason they type is the record.
  • 03Deployed in your cloud account or on your hardware, so the data never leaves your boundary.
  • 04You shape what gets built next. Design partners set the roadmap for the next judgment types we capture.
Talk to the founders

Your data.
Your boundary.

Most teams run Fynto inside their own cloud account. Teams with stricter obligations run it on their own hardware, with AI analysis routed to a model endpoint they control or switched off.

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Private Cloud Your cloud account
On-Premises
Who manages infrastructure Fynto Your team Your team
Where your data lives Our cloud Your cloud account Your data center
Data stays in your boundary
AI analysis Full Full Optional
Enterprise controls Standard Full Maximum
Best for Smaller teams Most teams Teams with strict data obligations

Audit workpapers, regulatory filings, credit memos.
Same shape, same judgment layer.

Any document rewritten every cycle about the same subjects, where a named person has to defend a closed set of positions, can run on the same record. Transfer pricing is where it is live today.

Talk to us about a design-partner engagement

Questions tax teams ask first.

Does the AI make the decisions?

No. The AI drafts proposals from the year's evidence and points at where each one came from. Every position in the report is confirmed, changed, or reverted by a named reviewer. Where the draft contradicts last year, the report is blocked until a person decides. There is no “confirm all” for those gates, and the recalled value is never pre-applied.

Does this replace our team's judgment, or our methodology?

It records your team's judgment. Your screening approach, your characterizations, and your method choices are the ones that get written down and brought back. Fynto makes the senior review a queue of specific questions instead of a re-read of the whole file, and makes a reviewer's reasoning outlast their tenure.

What does Fynto remember in our first year?

Whatever is in the prior-year report you upload. Fynto reads its transactions, functional analysis, and conclusions into the new file as proposals. Each one your team confirms becomes the first entry in the record for that subject. From the second cycle on, the draft is compared against those entries and the drift gates fire.

Do we need our own comparables database?

No. If your advisor delivers the benchmarking study, upload the accept/reject workbook behind it. If you license a database, export the search from it, or hand over the matrix your team already worked. Either way, Fynto records each accept and reject as a decision, computes the interquartile range from your rows, and carries it into the report. A study PDF rides along as evidence; the range is never quoted from it.

What happens to our positions when we change advisors?

They stay with you. The record lives in your Fynto workspace, not in your advisor's working papers. A new advisor, or a new member of your own team, opens the file and sees each position, who set it, and the reason they gave at the time.

Where does our data live?

In your cloud account or on your hardware, for the two deployment options most teams choose. Your documents, comparables, and the decision record stay inside your boundary. The AI analysis can be pointed at a model endpoint you control or switched off entirely for on-premises deployments.

What do we hand an examiner three years later?

For any position in the file: what it was, what the draft had proposed instead, who decided, when, the reason they wrote at the time, which documents they were looking at, and every re-decision since, in order. Open items are disclosed, not dropped.

See it on a sample file,
or one of your own.

A 30-minute walkthrough on our sample file. If you would rather see your own, we can sign an NDA first and use last year's report and this year's documents.