Reference · version 1.0 ·
FETP: the reference
Foresight-Enhanced Transfer Pricing (FETP) is a method, developed by Ajit Jain, for designing and reviewing a transfer pricing policy against several plausible futures. It runs in four phases: Perceive, Prospect, Probe and Transform.
The four phases
In order.
- 01Perceive
- Scan for signals of change in tax rules, audit practice, technology and the business model. Record each with its source and date.
- 02Prospect
- Build a small set of plausible futures from the open uncertainties, and map how functions, intangibles and risks could move in each.
- 03Probe
- Wind-tunnel the current policy: test each material position against every future.
- 04Transform
- Sort each position by how many futures it holds in, then set triggers and a response for those that depend on the future.
The three classes
How a position is sorted after the wind-tunnel test.
- Robust
- A position that holds in every future considered.
- Contingent
- A position that holds in some futures and not in others.
- Big bet
- A position that holds in one future only.
The outputs
What an FETP exercise produces.
- Signal register
- The list of signals found in the Perceive phase, each with source and date.
- Scenario set
- The futures used in the exercise, usually four.
- Wind-tunnel result
- A grid of positions against futures, showing where each position holds.
- Position card
- A one-page record for a material transaction: the position, its assumptions, its class, the triggers to watch and the planned response.
- Trigger
- An observable event or threshold that signals a future is arriving and a position should be reviewed.
How to cite
You are welcome to quote and cite this reference with credit.
This reference
Jain, A. (2026). Foresight-Enhanced Transfer Pricing (FETP): reference, version 1.0. Averise. https://www.averiseglobal.com/en/fetp
The paper
A. Kumar Jain, "Introduction of Strategic Foresight in Transfer Pricing: Turning Uncertainty into Competitive Advantage", International Transfer Pricing Journal 2025 (Volume 32), No. 5 (IBFD). https://doi.org/10.59403/239nqky
Files
Free to download.
© 2026 Averise. FETP is the work of Ajit Jain. This reference is general information and is not advice. FETP as a service.