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Transfer Pricing Screen (India)

screen_transfer_pricing
Read-only

Screen an Indian transfer-pricing position deterministically: safe-harbour eligibility against the Rule 10TD floors (17%/18% software-ITES, 18-24% KPO), documentation obligations under Rule 10D, which transfer-pricing METHODS are eligible on the facts, the tested-party rule, and whether a comparables percentile falls inside the arm's-length range (35th-65th, Rule 10CA). Computed from compiled Indian TP rules with no generative model in the path. Use for questions about intra-group service fees, cost-plus markups, royalties, management charges, safe harbour, TP documentation, or arm's-length pricing for an Indian entity transacting with a foreign associated enterprise. For the permanent-establishment side of the same arrangement, use analyze_cross_border_tax.

Input Schema

TableJSON Schema
NameRequiredDescriptionDefault
postureNo
questionNoThe user's original question, verbatim (optional but encouraged) — it improves the engine's coverage of real phrasings. Facts, not this field, drive the answer.
alrPercentileNoWhere the tested margin sits in the comparables set (percentile, 0-100).
assessmentYearNo
hasExternalCupNo
hasInternalCupNo
transactionTypeYese.g. 'Provision of Services', 'IP Licensing / Royalty', 'Contract Manufacturing', 'Distribution of Goods', 'Intra-group Financing'.
serviceMarkupPctNoDeclared cost-plus markup as a PERCENT (e.g. 12 for 12%). Drives safe harbour.
transactionValueCrNoTransaction value in INR crore.

TDQS

A4.6/5.0
Behavior5/5

Does the description disclose side effects, auth requirements, rate limits, or destructive behavior?

The description adds behavioral context beyond the readOnlyHint annotation: it says the tool operates 'deterministically' and 'with no generative model in the path,' which sets clear expectations about the nature of the output. It also clarifies that the 'question' field is optional and does not drive the answer—only facts do. No contradiction with annotations.

Agents need to know what a tool does to the world before calling it. Descriptions should go beyond structured annotations to explain consequences.

Conciseness4/5

Is the description appropriately sized, front-loaded, and free of redundancy?

The description is information-dense but every sentence carries weight—initial action, specific rules, usage scenarios, and sibling pointer. The list of topics is long but directly relevant; it avoids fluff and extra verbiage, though slightly longer than strictly necessary.

Shorter descriptions cost fewer tokens and are easier for agents to parse. Every sentence should earn its place.

Completeness5/5

Given the tool's complexity, does the description cover enough for an agent to succeed on first attempt?

Given the high complexity of Indian TP rules, the description covers the tool's core functionality, its deterministic nature, the types of questions it answers, and an explicit alternative. Even though there is no output schema, the enumeration of what it calculates (safe harbour, methods, tested party, arm's-length range) effectively communicates expected results. This is a complete and self-sufficient description.

Complex tools with many parameters or behaviors need more documentation. Simple tools need less. This dimension scales expectations accordingly.

Parameters3/5

Does the description clarify parameter syntax, constraints, interactions, or defaults beyond what the schema provides?

Schema coverage is 56%, and the description does not directly map to individual parameters beyond broad references (e.g., 'safe-harbour eligibility' implies serviceMarkupPct). The input schema already provides descriptions for key params like alrPercentile and transactionType. The description adds marginal context but does not clarify less-documented parameters such as posture or hasExternalCup, so it lands at the baseline.

Input schemas describe structure but not intent. Descriptions should explain non-obvious parameter relationships and valid value ranges.

Purpose5/5

Does the description clearly state what the tool does and how it differs from similar tools?

The description uses a specific verb ('screen') plus a clear resource ('Indian transfer-pricing position') and enumerates concrete outputs (safe-harbour eligibility, documentation obligations, eligible methods, tested-party rule, arm's-length range). It also distinguishes itself from the sibling tool analyze_cross_border_tax, making its purpose unambiguous.

Agents choose between tools based on descriptions. A clear purpose with a specific verb and resource helps agents select the right tool.

Usage Guidelines5/5

Does the description explain when to use this tool, when not to, or what alternatives exist?

Explicitly states when to use this tool ('Use for questions about intra-group service fees, cost-plus markups, royalties, management charges...') and provides an explicit alternative for the PE side ('use analyze_cross_border_tax'). This is textbook usage guidance.

Agents often have multiple tools that could apply. Explicit usage guidance like "use X instead of Y when Z" prevents misuse.

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TDQS

A4.7/5.0
Disambiguation5/5

Each tool has a clearly distinct purpose: analyze for specific fact patterns, lookup for abstract rule questions, list for coverage inquiry, screen for transfer pricing, and verify for checking analysis. The descriptions explicitly cross-reference each other to disambiguate when to use which, such as 'use analyze when you have a specific matter's facts' vs 'use lookup when the question is about the law in the abstract'.

Naming Consistency5/5

All tool names follow a consistent verb_noun pattern in snake_case: analyze_cross_border_tax, list_compiled_corridors, lookup_compiled_rule, screen_transfer_pricing, verify_tax_research_note. The verbs are distinct and the nouns clearly describe the resource or action.

Tool Count5/5

Five tools is well-scoped for this domain: coverage discovery, rule lookup, fact-based analysis, transfer pricing screening, and verification. Each tool earns its place without redundancy or bloat, matching the tightly defined purpose of the server.

Completeness5/5

The tool set covers the full workflow: discover what the engine covers, look up abstract rules, analyze specific cross-border arrangements, screen transfer pricing, and verify any research note. The refusal mechanism for out-of-scope topics ensures no dead ends, and the explicit links between tools make the surface complete for its stated legal reasoning purpose.