Validation Programme

We hold our methodology to the standard we ask of your documentation: claims require evidence.

Published architecture. The framework's full methodology — construct, aggregation, classification gates, coherence axioms, evidence model — is documented to peer-review standard. A methods article has been prepared for the World Tax Journal (IBFD), with a companion architecture for hard-to-value intangibles at the International Transfer Pricing Journal.

Independent standard-setting. Classification thresholds and gates are governed by the same procedures used for professional licensure examinations: a modified Angoff standard- setting process by an independent tripartite panel — former tax-administration officials, academics, and senior practitioners, with no constituency holding a majority — with a full published audit trail. The panel study is designed, budgeted and pre-registered before data collection.

Tested against reality. The validation design includes blind scoring of published, adjudicated transfer pricing disputes: independent professionals score the functional facts without knowing the outcome, and the framework's classification is compared with the adjudicator's characterisation. An internal feasibility pilot (July 2026, four adjudicated disputes, balanced outcomes) confirmed the instrument applies cleanly to judgment facts and returned a 4/4 direction-concordance signal — reported here for what it is: an encouraging pilot, not the study. The full study, with independent blind scorers and a pre-registered analysis plan, is the credential we are building — and we will publish it whatever it shows.

Status current as of July 2026. This page is updated at every methodology version release.