Live now in transfer pricing

The Judgement Layer
for AI-drafted documentation.

Recurring, defensible documents get redrafted every cycle. Fynto captures every reviewer decision and brings it back next cycle — as a question when the draft disagrees, an offer when it doesn't. Never as an answer.

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Documentation runs on cycles.
Judgement runs in one head.

Transfer pricing reports, audit workpapers, regulatory filings, credit reviews — all written every year about mostly the same subjects. The report records the conclusion, not the alternatives considered or the evidence weighed. When the person moves on, so does the file.

Today's options

Every AI drafting tool picks one of these. Both fail defensibility.

Regenerate from scratch. Reflects this year's evidence, and drift goes unnoticed until a reviewer happens to compare against last year's file.
Roll last year's positions forward. A stale position propagates because nothing prompts anyone to revisit it — and the error compounds precisely when personnel turn over.

How Fynto handles it

Always draft from this cycle's evidence. Also remember, durably and with context, every judgement a human made last cycle.

Where the two disagree, the layer stops and asks. A blocking gate names the prior position, who set it, and last cycle's rationale. Confirm the change, revert to prior, or leave open.
Reuse of a prior call is one click, and the click is recorded. The recalled value is an offer, never a default. Nothing is silently reapplied.
Every decision is one append-only row. Re-decisions don't overwrite; they supersede. Open items carry forward, so “leave open” never becomes “forgotten”.

Software forgets.
Fynto remembers.

The compounding advantage

One connected chain of reasoning

Analysis flows through a single connected pipeline — so every number in the final report traces back to the evidence that produced it, and every remembered judgement knows exactly where it belongs next year.

Evidence → Controlled Transactions → FAR Analysis → Characterisation → Tested Party → Method → Benchmarking → Report

A ledger of decisions,
beside the drafting agents.

Drafting agents extract this cycle's positions from this cycle's evidence. They do not know the ledger exists. The review workflow, where a human confirms or corrects the agent's output, is the only writer and the only reader. That independence is what makes cross-cycle comparison meaningful.

One decision, one row

Every gate answer, dropdown pick and text save becomes one append-only row. Same shape regardless of what it's about — so a new kind of judgement is a key function and a gate, not a schema migration.

"business_key": "far|acme services gmbh|it_support",
"topic": "far_characterization",
"fiscal_year": 2025,
"prior_value": "limited_risk_service_provider",
"chosen_value": "entrepreneur",
"disposition": "confirmed_change",
"rationale": "Acme took on DEMPE functions
                for the platform IP in FY2025.",
"supersedes_decision_id": null,
"context": { /* agent proposal, evidence, source */ }

No auto-carry, no inferred identity, no bulk confirmation, no feedback loop into extraction. The recalled value is an offer, never a default.

What the ledger remembers today

The ledger is generic. It currently captures four kinds of judgement inside the transfer pricing workflow — and the storage layer didn't change when we added the fourth.

Transaction treatment
How was this controlled transaction characterised?
Method selection
Which pricing method applies to this transaction?
Functional characterisation & narrative
What is this entity's functional profile, and what did the reviewer write about it?
Comparable treatment
Was this comparable company accepted or rejected, and why?

Three moves,
every cycle.

The layer runs when a reviewer opens a workflow step, and again on every decision they make.

1

Identify the subject

A business key from stable external references — ERP refs, agreement codes, registrant ids. If it doesn't resolve to exactly one subject on both sides, we skip. A recall gap, never a false flag.

2

Gate on drift

A genuine position change becomes a blocking gate: confirm, revert, or leave open. Revert restores the prior value server-side. No model between the reviewer's click and the row that gets written.

3

Offer, then write

Where there's no contradiction, last cycle's value and rationale sit under the current one with a Reuse button. Every reviewer action — gate, edit, reuse — is one append-only row.

Transfer pricing,
end to end.

Several dozen controlled transactions. A handful of entities characterised across categories. A benchmarking study that screens hundreds of candidate comparables down to twenty. Almost every item is a human call that has to be defended to a tax authority, sometimes years later.

Bring your own benchmark.
Fynto finishes the report.

Fynto works with the comparables database you already license — no new subscription, no switching. Export the search output, or hand over the accept/reject matrix your advisory firm already worked, and Fynto screens it, records every accept and reject as ledger rows, computes the arm's-length range, and carries the result through method selection into the report.

Uploaded comparables live in your workspace only. Every accept and reject is one row keyed by the normalised company name — so next cycle a rejected comparable comes back with its reason.

fynto / benchmarking / FY2025 / import Rights attested
Import doors
.xlsx
Raw search export
Fynto runs the screens. A screen it couldn't run is marked “never ran” — not assumed.
.xlsx
Worked accept/reject matrix
Your firm's accept/reject decisions adopted as-is, reasons kept, gaps left open for review.
.xlsx
Price schedule (CUP)
Comparable prices go straight to the range. No financials step.
Arm's-length range · interquartile Tested party operating margin 8.2% · within range
25th 75th
A study PDF rides along as evidence; the range itself is computed from your rows — never quoted.

Audit workpapers, regulatory filings, credit memos.
Same shape.

A stable subject, a closed set of positions, a named human, and a reason. The ledger already has the columns.

Talk to us about a design-partner engagement

Your infrastructure.
Your rules.

SaaS
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Private Cloud Your VPC
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 Mid-market Enterprise Regulated / Tax-sensitive

Give your judgement
a lifecycle of its own.

A 30-minute walkthrough of the Judgement Layer, on your data.