Big 4 Partner Experience
Sunil Agarwal, Shane McEvoy and Andrew Fairfoull bring decades of Big 4 partner-level experience across the Americas, Europe and APAC.
Transfer Pricing Masterclass
With BEPS 2.0, a 15% global minimum tax, substance-based carve-outs, and Amount B reshaping the rules, where your group creates value now drives both your arm’s-length defensibility and your effective tax rate at the same time.
The uncomfortable question for most groupsDoes your value chain still tell a coherent story, and would it survive an IRAS or foreign authority challenge today?
Over this Masterclass, Sunil Agarwal, Shane McEvoy and Andrew Fairfoull, with decades of Big 4 partner experience across the Americas, Europe and APAC, cut past the jargon and show you how a dynamic, evidence-backed value chain becomes your defence shield. You will leave with a practical lens for stress-testing your own TP footprint.
Why You Should Attend
Sunil Agarwal, Shane McEvoy and Andrew Fairfoull bring decades of Big 4 partner-level experience across the Americas, Europe and APAC.
See how a dynamic, evidence-backed value chain becomes your defence shield under BEPS 2.0, the 15% global minimum tax, and Amount B.
Leave with a practical framework for stress-testing your own transfer pricing footprint against an IRAS or foreign authority challenge. Recent cases on Coke, Netflix, Meta, Pepsi, etc will be discussed.
Video Library
Sessions from infer360’s partners on defending your transfer pricing, with more added as they are recorded.
Register once to unlock every video.
Sunil Agarwal on how transfer pricing is shifting from a compliance exercise to an end-to-end, defence-ready approach — and how infer360's data, operations and intelligence layers build an enterprise tax memory that holds up when challenged.
Andrew Fairfoull on how best-in-class companies stay in control when transfer pricing queries and audits arise, and how infer360 brings together institutional knowledge, value chain analysis and analytics to support defence readiness.
Latest Thinking
Transfer pricing intelligence: practical insight on documentation, operational TP and strategic value chain planning.
Stay informed with our latest insights
The Year-End True-Up Trap: What It Reveals About Transfer Pricing GovernanceA year-end true-up may restore the appropriate arm's-length outcome, but it does not answer the governance question: could the drift have been identified earlier?Read More 
The Magnifying Effect of AI on Transfer Pricing DisputesThe better question is whether defence readiness can be built into the transfer pricing ecosystem before the dispute begins.Read More 
AI and the Democratisation of Tax Risk ManagementIf the business is changing continuously, can transfer pricing risk still be managed periodically?Read More 
The Tariff-Tax CollisionOptimising customs duties without evaluating the transfer pricing impact creates an invisible compliance trap. A unified value-chain simulator protects margins from both authorities at once.Read More 
The Intercompany Memo 1Static, years-old transfer pricing documentation is no longer a defence — it is an invitation for adjustments. How an OECD-aligned document engine keeps your narrative synchronised with operational reality.Read More We are a collective of former Big-4 partners, data engineers, and global policy experts. We believe that in a world of increasing tax complexity, “Simple” is a superpower. We build the tools that give tax leaders their time—and their strategy—back.
