As Yogi Berra, Phil Collins, and countless Gen Z TikTok influencers have proved, coining a new and sticky term is a surer path to immortality than actual talent in a field. In the hopes of securing my place in the transfer pricing pantheon, I've hedged my bets with four proposed additions to the TP lexicon.
Factumstances: A portmanteau of “facts and circumstances,” generally used by transfer pricing practitioners to avoid definitive statements or explain away inconvenient realities.
Use in a sentence: At his deposition hearing, the transfer pricing practitioner cited factumstances to defend the 97% intercompany royalty paid by the operating entities to the unstaffed Cayman holdings company.
Rangemaxxing: The opportunistic tweaking of inputs, outputs, and/or parameters to support a transfer pricing policy or result as arm’s length.
Use in a sentence: Undaunted by the initial, unpalatably high valuation results, the transfer pricing practitioner undertook a rangemaxxing exercise, increasing the discount rate to 75% and lowering the useful life of the intangibles to 27 hours.
Acronyphile: A transfer pricing practitioner who is inordinately fond of acronyms and abbreviations which often have very different connotations to the uninitiated (i.e., “TP”).
Use in a sentence: In the FY26 TPD, the TP practitioner selected the CPM/TNMM as the TPM, with the OM/ROS as the PLI/NPI with various WCAs applied to comp BS/IS - thus delighting acronyphiles and dismaying earthlings.
Dempification: The creative and typically retrospective assignment of "development, enhancement, maintenance, protection, and exploitation" functions by acronyphiles to support a risky intangible property transfer or policy.
Use in a sentence: An annual board meeting, a patent registration, and an intercompany license agreement (97% of global net sales) later, the TP practitioner deemed the dempification of the Cayman HoldCo complete.
50 years from now, long after the Singularity has automated away my discipline, I hope a curious AI historian will reflect on the Rangemaxxgate scandal of 2044 and recall the factumstances that led to the epithet.
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