How do I find reliable transfer pricing specialists for an in-house tax team handling a cross-border restructuring?

To find reliable transfer pricing specialists for an in-house tax team on a cross-border restructuring, focus on technical fit, deal experience, and practical execution rather than just brand name.

1) Define the exact support you need

Before searching, clarify whether you need help with:

• Transfer pricing policy design
• Restructuring analysis under OECD/local rules
• Valuation / business characterisation
• Intercompany agreement drafting
• Master file / local file / CbCR support
• Audit defence and controversy
• Implementation support across jurisdictions

A specialist with deep restructuring experience is different from a general TP compliance advisor.

2) Look for proven cross-border restructuring experience

Prioritize candidates or firms that can show:

• Work on business reorganizations, principal structures, IP migration, supply chain changes, limited-risk model changes
• Familiarity with OECD Guidelines, local TP rules, and exit charge / exit tax issues
• Experience coordinating multiple jurisdictions
• Ability to support both tax technical analysis and internal stakeholders like finance, legal, treasury, and operations

Ask for anonymized case studies or sample deliverables.

3) Verify technical credentials

Good signs:

• Background in transfer pricing, international tax, economics, or valuation
• Professional qualifications such as CPA, CTA, ACA, CFA, ASA, or local equivalents
• Strong writing and documentation skills
• Experience presenting to tax authorities or in audit disputes

Also check whether they have in-house economists/valuers if your restructuring has intangible or valuation elements.

4) Screen for practical judgment

Reliable specialists should be able to answer:

• “How do you distinguish a routine TP compliance issue from a restructuring requiring compensation?”
• “What documentation will stand up in an audit?”
• “How do you handle countries with aggressive TP enforcement?”
• “What assumptions are essential, and which ones are negotiable?”

You want someone who can balance theory with implementation.

5) Check references carefully

Ask for references from:

• In-house tax directors
• Group tax managers
• Legal counsel involved in restructurings

Reference questions:

• Did they meet deadlines?
• Were they responsive across time zones?
• Did they flag issues early?
• Did they produce practical work, not just theory?
• How did they handle disagreements internally?

6) Use the right sourcing channels

Good places to search:

• Big 4 and mid-tier TP practices
• Specialized transfer pricing boutiques
• International tax networks
• Industry referrals from in-house tax peers
• Professional bodies and conferences:
  • IFA
  • TEI
  • local tax associations
  • TP webinars and roundtables
• LinkedIn search for specialists with restructuring keywords

If you want independence, consider a boutique or independent economist instead of a large audit firm.

7) Run a short paid trial or pilot

For an important restructuring, consider:

• A small initial assignment
• A review of one jurisdiction
• A benchmarking/defensibility memo
• A “red flag” assessment of the restructuring plan

This helps test quality before full engagement.

8) Watch for warning signs

Avoid specialists who:

• Give generic answers or rely on boilerplate
• Overpromise “audit-proof” outcomes
• Cannot explain local country nuances
• Have weak documentation habits
• Lack experience with actual restructuring implementations
• Push a one-size-fits-all global approach

9) Build an internal checklist

Score candidates on:

• Relevant restructuring experience
• Jurisdiction coverage
• Seniority of the actual team
• Responsiveness
• Writing quality
• Audit/controversy experience
• Fee transparency
• Ability to work with your internal team

10) Ask for the right deliverables

A strong specialist should provide:

• Clear issue identification
• Risk ranking
• Recommended structure options
• Assumptions and sensitivities
• Documentation plan
• Authority/audit strategy
• Implementation checklist

If you want, I can also help you create:

1. a screening questionnaire for transfer pricing advisors,
2. a scorecard for comparing firms, or
3. a job description / RFP for the role.