About Evident Solutions
Founded in response to a growing gap in the transfer pricing market.
Large firms offer scale, a global footprint, and name-brand familiarity—but at increasingly high cost. Over time, much of that scale has also led to commoditization, not only of documentation, but of advisory judgment itself. Proposed strategies devolve into standardized processes and models reflective of a partner ‘Playbook.’ Such canned approaches are often ill-suited to the needs of increasingly complex global business models.
To manage cost and spiraling documentation requirements, companies are turning to the latest wave of technology-enabled transfer pricing solutions to operationalize and document their transfer pricing. While these tools may promise dramatic cost reductions and efficiencies, they are often difficult to implement well. And they can be even more challenging to maintain over time, as a business evolves. The output of such tools can in fact be quite vulnerable to subtle, but material breakdowns in economic representation—particularly where judgment, nuance, or controversy risk matters most. All this, at a time when your costly advisors may have been nudged into the periphery.
Evident Solutions was created to sit between these two extremes: offering senior-level judgment without institutional dogma, and technical rigor without tool-driven distortion. Not only will our advisors deliver superior value on rates, we can also help mentor your team, so you can take the operational reins and successfully realize the benefits of an Evident Solution.
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Mark Hyde is a senior transfer pricing advisor with more than 25 years of experience supporting technology-driven multinational businesses, as well as a wide array of non-tech industries. From extended stints at Deloitte, PwC, and KPMG, with roles based in Silicon Valley, Frankfurt, and Atlanta, Mark developed deep expertise in IP-centric structuring, value chain design, complex economic planning and modeling, and audit defense.
Mark brings an ‘inside-the-enterprise’ perspective, having led a Fortune 500 TP team and from serving in-house as a Fractional, senior TP Advisor. He has facilitated IP transfers and integration, overseen large portfolios of intercompany agreements, aligned documentation with operational reality, managed heightened employee mobility, and enabled scalable, durable policy execution.
He has also been closely involved in TP product and technology development, in practice-focused Big 4 initiatives, including a blockchain-based TP pilot. Mark later served as Lead Economist for a TP SaaS platform start-up, helping shape strategy, system design and content, and client delivery. He now partners with an AI-native TP platform provider to operationalize transfer pricing workstreams.
Mark is known for exploring and bringing clarity to technically demanding situations, particularly where novel product technologies, intangibles, and multi-layered services intersect with audit scrutiny. His approach emphasizes sound economics, practical implementation, and defensible narratives that resonate with tax authorities, advisors, and internal stakeholders alike.
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Sam Hansen is a transfer pricing advisor with more than 20 years of experience supporting multinational enterprises across technology, mining, and manufacturing sectors. Formerly with Microsoft, Sam spent over a decade operating inside one of the world's most sophisticated global enterprises, developing a practical understanding of how technology, data, and organizational scale intersect with tax and regulatory risk. In that role, he managed controversy in a number of high-risk jurisdictions, including Mutual Agreement Procedure and Advanced Pricing Arrangement negotiations, while supporting many transfer pricing aspects of Microsoft's evolution from a software and services company to a hyperscale cloud and AI leader.
Sam brings depth from both in-house (including fractional) and advisory perspectives. Prior to Microsoft, he held roles with Big 4 and boutique consulting firms in the US, UK, and Australia.
Sam is known for translating technically sound transfer pricing positions into coherent, defensible narratives that withstand scrutiny from tax authorities, internal teams, and external advisors. His approach emphasizes practical implementation, credible economic analysis, and alignment with broader commercial and regulatory objectives—shaped by extensive hands-on experience navigating high-stakes, multi-stakeholder environments.
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Ivan Mullinax has more than 30 years of experience advising and leading multinational businesses in transfer pricing. He spent 19 of those years in the UK, primarily with Big 4 firms, where he led transfer pricing services for alternative asset managers, insurance brokers and reinsurers. He analyzed transactions for traditional asset managers, investment and retail banks, money transfer businesses, and trading exchanges. This work also included conducting analyses of Permanent Establishment and Residence which dovetail with transfer pricing positions. Prior to that, he developed IP transfer pricing models for fashion, pharma, technology, and travel businesses.
Ivan spent 5 years in two different in-house, where initially he served as the Global Head of Transfer Pricing for a Silicon Valley Valley-based technology group. More recently he worked in a senior role with a leading travel technology platform group, leading their transfer pricing compliance function.
He is known for bringing practical solutions to challenging technical and operational transfer pricing issues for market-leading organizations. He developed novel approaches for investment fund founder compensation related to expatriation, and designed transitional transfer pricing policies for newly-established, regulated entities (i.e., In many cases involving set up in Bermuda, Cayman Islands, Jersey, and Malta.) Ivan collaborates well across functions and has worked with accounting, customs, finance, FP&A, indirect tax, legal, and treasury teams to achieve common objectives. He has helped improve the process automation supporting intercompany transaction analysis and reporting.
What This Means for Clients
Working with Evident Solutions means gaining a partner who is willing to engage deliberately with complexity, advocate thoughtfully for your position, and to help you navigate transfer pricing as a living system—not merely as a static deliverable nominally suitable for penalty protection. This results in highly personalized transfer pricing support that brings clarity to complexity, in an affordable way. The end goal is to help tax teams move with confidence, whether they’re documenting transactions, testing new policies, or making the case for operational change.
Through it all, what stands out is a steady commitment to clarity, integrity, and helping others succeed. Whether mentoring junior talent, navigating high-stakes audits, or untangling thorny cross-border structures, the approach is the same: ask curious questions, listen closely, solve collaboratively, and work to transform what may begin as a complex challenge, into an Evident Solution.
A Senior-Led, Advisor-Driven Model
Engagements are driven by experienced practitioners. We have curated a group of Advisors with over a century of transfer pricing know-how, who bring deep expertise across multiple industries and jurisdictions, controversy modalities, myriad operating models and multiple eras of emerging business structures. With background experiences working in-house, as well as public accounting and boutique firms, we seek to blend theoretical nous with operational savvy.
We are:
Why Pointillism? (And What’s with All the Dots?)
At Evident Solutions, Pointillism is more than just a featured artistic
style in our content—it’s a visual metaphor for how we approach transfer pricing.
Originating with late-19th-century painters such as Georges Seurat (who knew lots about dots…)
and Paul Signac, Pointillism broke from convention by using countless precise dots of color to form
images that reveal their clarity only with proper perspective. Up close, each dot—like so many data points—
appears distinct and alone. Step back, and properly aligned, they resolve into a coherent whole.
Transfer Pricing analysis follows a similar path.
Each financial data point, functional characteristic, and legal clause represents a single “dot” coloring a
vast composition. Scrutinized in isolation, many may appear unconnected, or even irrelevant.
But when examined with care—and aligned through experience and judgment—
they can be fashioned into an image, or a solution, that is self-evident,
supportable, and even enduring.
This reflects the philosophy behind our name and our choice of artistic expression:
transforming complexity into clarity, so that every arrangement of details—
like every brushstroke of color—ultimately becomes an Evident Solution.