Filing-grade tax analysis without sending pre-filing positions to a third-party model.
Transfer pricing documentation, tax provision workpapers, R&D credit studies and IRS audit responses are statutory-privileged information. Sending them to a US-based AI vendor is itself a §6713 risk. This agent reads them inside an Intel TDX hardware enclave, under a French controller, validates arm’s-length pricing, models BEPS Pillar Two exposure and structures audit defense. Built for multi-jurisdiction tax teams that cannot leak pre-filing positions.
Built for: VP Tax, Transfer Pricing Directors, Tax Provision Managers, Big Four international tax partners
Transfer pricing documentation costs $100-500K annually from Big Four advisors. IRS TP adjustments average $10M+ per case. Pillar Two compliance now affects 8,000+ MNE groups. Pre-filing tax data on shared AI infrastructure is an unacceptable risk for any Fortune 500, yet manual review is the bottleneck.
Validate transfer pricing benchmarking, run Pillar Two GloBE ETR calculations and structure audit defense in hours, with pre-filing tax data sealed in hardware.
What the Tax & Transfer Pricing Analyst does on every document, sealed inside an Intel TDX hardware enclave.
Validates Local File, Master File and CbCR against OECD 2022 guidelines and IRC §482. Flags methods that would fail Best Method Rule, comparables with material adjustments and intercompany agreements that do not match actual conduct.
For each transaction: validates CUP / TNMM / profit split / resale price / cost plus selection. Checks PLI calculation, interquartile range, year-over-year consistency. Surfaces patterns like "tested party always at bottom quartile" a profit-shifting signal.
Calculates effective tax rate per jurisdiction, flags ETR below 15%, models top-up tax exposure under QDMTT / IIR / UTPR, applies transition rules and safe harbors. For groups with >€750M revenue.
Reviews uncertain tax positions under FIN 48 / IFRIC 23, valuation allowance assessment, rate reconciliation completeness, indefinite reinvestment assertion support, stock comp excess tax benefit treatment.
Walks each claimed activity through the IRC §41 four-part test (permitted purpose, technological uncertainty, process of experimentation, technological in nature). Flags activities the IRS aggressively challenges post-§174 capitalization.
Builds the defensibility scorecard for each position: authority level (statute > regs > court > rev rul > PLR), risk of adjustment, penalty exposure, reasonable-cause defense, adequate-disclosure analysis.
Four steps from upload to export. Your document is decrypted only inside the CPU-encrypted enclave.
TP Local File, Master File, CbCR, benchmarking study, intercompany agreement, ASC 740 workpaper, R&D credit study, IDR response. TLS in transit, decrypted only inside the TDX enclave.
Tax data is processed in CPU-encrypted memory. The cloud operator cannot read pre-filing positions or workpapers during analysis. The controller is French; compute sub-processors are US-based and listed, and the sealed memory is what limits what any of them can hand over.
Tax analysis summary, transaction matrix, method validation, BEPS Pillar Two table, provision review, R&D qualification table, audit defensibility scorecard. Every position cites the specific code section.
Markdown for partner review, JSON via API for ONESOURCE / Corptax / Longview integration, tables for the provision workpaper binder.
Every output cites the specific article, section or control. The Intel TDX hardware boundary handles the data-protection side; the agent handles the analytical side.
Real prompts from tax / transfer pricing teams.
Review this TP documentation, is our benchmarking defensible under IRC §482?
Assess our BEPS Pillar Two exposure. Which jurisdictions trigger top-up tax?
Analyze this R&D credit study, which activities actually qualify under the 4-part test?
We received an IRS IDR on our transfer pricing. Help structure the defense.
Prompt: Calculate our GloBE effective tax rate for each jurisdiction in this CbCR.
Output: Ireland: ETR 9.2%, below 15% GloBE threshold, top-up tax ~$4.2M (subject to QDMTT priority). Luxembourg: ETR 8.4%, below threshold, top-up tax ~$2.1M. Singapore: ETR 13.7%, below threshold, top-up tax ~$1.1M (Singapore QDMTT in effect from 2025). Total estimated Pillar Two exposure: ~$7.4M before transition safe harbors. Recommend transitional CbCR Safe Harbor analysis on Ireland and Luxembourg given simplified ETR computation may yield ≥15%.
Prompt: Is this 2% intercompany loan arm's length?
Output: NO, at 2% the rate is materially below arm’s length for an unsecured 5-year intercompany loan to a BBB-equivalent affiliate. Treas. Reg. §1.482-2(a)(2) safe harbor range for the period: 4.8-7.2%. IRS §482 adjustment risk: imputed interest of ~$1.8M/year, plus §6662(e) transactional penalty (20% if substantial understatement, 40% if gross). Recommend retroactive credit memo to restate to arm’s-length rate before year-end, with contemporaneous benchmarking documentation.
Every tier runs inside Intel TDX hardware enclaves. Plans stay in sync with /pricing.
1,000 requests/month, 1 seat. For solo tax practitioners, fractional tax directors.
3 seats, 2,000 requests/month, 100 MB uploads, audit log. For mid-market tax teams.
10 seats, 5,000 requests/month, 500 MB uploads, API access for tax provision integration, 12-month audit log retention.
Unlimited seats, fine-tuning on your TP playbook and provision methodology, SSO/SAML, dedicated TDX capacity, signed DPA, EU-hosted customer database.
Honest comparison. Hardware-rooted confidentiality is what most alternatives are missing.
| Alternative | Pros | Cons vs VoltageGPU |
|---|---|---|
| Aibidia |
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| ONESOURCE / Corptax |
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| ChatGPT Enterprise |
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Yes. Inference runs inside Intel TDX hardware enclaves with CPU-encrypted memory. The cloud operator cannot read prompts or workpapers during processing. The architecture mitigates §6713 preparer-disclosure risk and protects MNPI tax positions better than any shared-infrastructure SaaS.
Big Four TP and provision support runs $300-800/hr fully loaded. A full TP documentation engagement costs $100-500K annually. The agent does not replace partner sign-off, but it compresses the analyst hours that make up the bulk of the engagement fee. Most customers retain their Big Four firm for opinion-level work.
Yes. Coverage includes GloBE jurisdiction-level ETR, top-up tax computation under QDMTT / IIR / UTPR, transition safe harbors (CbCR Safe Harbor, Simplified Calculations), substance-based income exclusion and BEPS Pillar One Amount A/B context. The agent will flag where simplified calculations differ from full GloBE methodology.
The agent builds the defensibility framework, authority hierarchy, penalty exposure, reasonable cause and adequate disclosure analysis. Final positions and opinion letters remain attorney/CPA work product. Output is framed as "analysis of technical merits and risks for review by tax counsel."
Yes, on the Pro tier via the OpenAI-compatible API. Customers use it to auto-review intercompany agreements before signature, batch-screen Local Files for benchmarking gaps and pre-flight provision workpapers before quarterly close.
The agent screens cross-border arrangements against DAC6 hallmarks (A1-A4, B1-B3, C1-C4, D1-D2, E1-E3) and flags reportable transactions. For DAC7 platform reporting, it can review platform terms against the reporting obligations.
Yes. The agent handles both US (IRC §482) and OECD methodologies on cross-border transactions, including the France-US tax treaty articles, French CFC (Art. 209B), the DGFiP audit posture and 2024-2026 French transfer pricing penalty regime updates.
A standing Big Four TP engagement runs $100-500K/year for mid-market multinationals. The Pro tier ($14,388/year) supplements that, typical effect is a 30-50% reduction in advisor hours billed, particularly on benchmarking refreshes and routine provision support.
Intel TDX attestation, EU jurisdiction, French operator (VOLTAGE EI). Cancel anytime.