Technology & Innovation · 9 min read
The idea for what eventually became TP Doc Gen AI didn't arrive in a boardroom. It arrived at close to midnight, in our Hyderabad office, watching two of our brightest transfer pricing associates rebuild — almost from scratch — a benchmarking structure they had already built for a nearly identical client three months earlier. Same industry. Same functional profile. Different company name at the top of the document. I remember standing near the door with a cup of filter coffee that had gone cold an hour ago, thinking: we are paying two exceptionally capable people to re-solve a problem we have already solved.
The Hiring Trap Nobody Warns You About
There's an assumption baked into how most professional services firms grow, mine included in the early years: if the work is increasing, hire more people who can do the work. It's not a wrong instinct. For a long time, it's the only lever you have. But somewhere past a certain size, I noticed it stops being a growth strategy and starts being a treadmill — you hire, you train for months before someone is fully productive, client volume grows anyway, and you're back to hiring again. The firm grows, but it never gets structurally faster. It just gets structurally bigger, which is not the same thing.
That midnight moment with the two associates crystallised something I'd been circling for a while: a genuine share of transfer pricing documentation — Master Files, Local Files, Country-by-Country Reports under the BEPS three-tier framework, reconciliations for filings with the Income Tax Department — is structurally repeatable. It requires a CA's judgment to sign off on, but the underlying construction of it doesn't need to be reinvented every single time it superficially looks new.
Building It Ourselves, Badly, at First
We could have bought an off-the-shelf tool. We looked at a few. None of them understood what I actually wanted encoded, which was closer to twenty years of pattern recognition from real disputes — the kind you only get from sitting through 50-plus ITAT appeals and watching which comparable-selection arguments actually hold up under cross-examination versus which ones only sound good on paper. A generic software vendor doesn't have that. We did, distributed across a decade and a half of case files. So we decided to build TP Doc Gen AI ourselves, first for our own India practice and then, as our Dubai entity, SBC Tax Consulting LLC, took on more GCC mandates from 2023 onward, for cross-border documentation as well.
The first internal version of it was, honestly, not good. It over-templated things it shouldn't have and under-flagged risk in places a junior associate would have caught instinctively. Feedback from within our own team, fairly early on, was blunt: we'd built an expensive way to make the same mistakes faster. That was a useful thing to hear, even though it stung a little at the time. We rebuilt the risk-flagging logic almost entirely after that.
What Came After the First Version
It got better because we kept feeding it real, resolved disputes rather than theoretical rules — which is a slower, more expensive way to build software than most people assume, but it's also the only way I trust. Alongside it we built Taxmate for direct tax and TRACES reconciliation, Fixtag for fixed-asset geo-tagging, SBC AUD Pro for audit automation, and SBC Track for tracking regulatory change across jurisdictions — each one born from a version of that same midnight realisation: somewhere, our best people were re-solving a problem the firm had already quietly solved before.
The Part That Still Makes Some Peers Uneasy
More than one peer, over the years, has suggested — not unkindly, more out of genuine puzzlement — that a tax firm has no real business spending this kind of money on software. I understand the instinct behind that. Our profession is, structurally, a conservative one, and OECD's evolving BEPS and Pillar Two guidance already asks practitioners to keep up with enough change without also rebuilding their own tooling. But I think that puzzlement is exactly the gap. The firms treating their case history as disposable institutional memory — something that walks out the door whenever a senior person leaves or retires — are, I'd argue, sitting on an asset they don't realise they have.
What the Bet Eventually Bought Us
I won't pretend any of this was chasing a certificate. But a few years in, this bet on building rather than buying — alongside genuine engagement with policy through forums like ICAI's CITAX pre-Budget representations — became part of what supported SBC being recognised, under DPIIT's Startup India framework — to our knowledge, the only consulting or advisory firm in India currently holding the 80-IAC startup tax exemption — a statutory acknowledgment, essentially, that we were running a technology-driven model and not just a traditional practice with a website. Around the same period, SBC was named to the TaxTech 500 for tax-technology leadership, our Dubai office was certified a Great Place to Work in the UAE from January 2025 to January 2026, and we became an independent member of Kreston Global, connecting us into a wider international accounting network beyond what any single firm our size could build alone.
None of that was the goal when I was standing by that door with cold coffee at midnight. The goal was simply not wanting to watch two good people solve the same problem twice. The recognition arrived afterward, almost as a side effect of doing the harder thing first.
The firms that treat hard-won case experience as something that quietly leaves with every departing senior professional are sitting on an asset they don't know they have.
Key Takeaways
- Hiring alone eventually becomes a treadmill — the firm gets bigger, not structurally faster, once client volume outpaces training time.
- A meaningful share of transfer pricing documentation work is repeatable and rules-based, even though it requires a CA's sign-off — a strong candidate for automation without losing judgment.
- SBC built TP Doc Gen AI, Taxmate, Fixtag, SBC AUD Pro, and SBC Track from real, resolved case history rather than generic rules — an expensive but more trustworthy approach.
- That technology-first bet contributed to SBC becoming, to our knowledge, the only advisory firm in India holding the DPIIT-recognised 80-IAC startup tax exemption, alongside a TaxTech 500 listing, Great Place to Work UAE certification, and independent membership of Kreston Global.
- Treating decades of litigation and documentation experience as a disposable, person-dependent asset is a common and costly blind spot in professional services firms.
Frequently Asked Questions
How is AI used in transfer pricing documentation?
AI-powered platforms can automate the structured, repeatable portions of Master File, Local File, and Country-by-Country Reporting preparation under the BEPS three-tier framework, freeing senior professionals for judgment-intensive work such as benchmarking strategy and dispute defence.
Why don't more CA firms in India build their own technology platforms?
It requires accepting a slower, more failure-tolerant development process than most compliance-driven practices are used to, and treating decades of case experience as a data asset worth investing in — a cultural shift as much as a financial one.
What is the 80-IAC exemption and why does it matter for advisory firms?
The 80-IAC exemption, administered under India's DPIIT/Startup India framework, provides tax benefits to recognised startups. A consulting firm holding it signals that its underlying model has been formally recognised as innovation-led rather than a traditional practice.
Continue the Conversation
This is the third in a series on building a top-tier tax and transfer pricing advisory in India. Catch up on leaving a Big 4 career to start over from zero and the difference between a CA who practices and one who builds an institution, or explore the full SBC product suite. To discuss technology-enabled transfer pricing or tax advisory for your organisation, start a conversation with the SBC team.
Editorial note: This article reflects general professional perspective and personal reflection. It is provided for informational purposes only and does not constitute tax, legal, or financial advice for any specific matter — please consult directly with a qualified professional about your own facts and circumstances. Any client or matter scenarios described are illustrative composites, with identifying details changed or generalised to protect confidentiality; they do not describe a specific, identifiable client, case, or engagement.