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Operational transfer pricing

Most adjustments are not caused by bad economics but by weak execution. Operational transfer pricing is the machinery that turns a policy into booked, reconciled, auditable intercompany results.

Operational transfer pricing

7 min

The processes, systems and controls that turn a transfer pricing policy into invoiced, booked and reconciled intercompany results.

Intercompany agreements

6 min

The legal contracts between group entities that set out the terms of intercompany transactions and underpin the transfer pricing policy.

Intercompany invoicing

6 min

The process of issuing and recording invoices between group entities for goods, services or licences delivered under a controlled transaction.

Intercompany accounting

6 min

The ledger processes for recording, eliminating and reporting transactions between entities in the same corporate group.

Intercompany netting

5 min

The practice of offsetting multiple intercompany payables and receivables between group entities into a single net settlement.

Intercompany reconciliation

6 min

The process of confirming that intercompany balances, invoices and pricing recorded by both counterparties to a transaction agree with each other.

Intercompany VAT

6 min

The value-added tax treatment applicable to invoiced intercompany transactions such as management fees, service charges and licence fees.

Management fees

6 min

Charges levied by a parent or head-office entity on subsidiaries for centrally-provided management, administrative or strategic services.

Low value-adding intra-group services

7 min

A defined category of supportive intra-group services eligible for a simplified 5% cost-plus mark-up under OECD Chapter VII, without full benchmarking.

Cost allocation keys

6 min

The metrics used to distribute pooled shared costs among group entities in proportion to their expected use or benefit.

Service charge allocation

6 min

The end-to-end methodology for building a shared-service cost pool, applying allocation keys, and charging the resulting amounts to recipient group entities.

Shared service centre pricing

6 min

The transfer pricing methodology applied specifically to centralized shared service centres delivering finance, HR, IT or procurement support across a group.

Hourly rate benchmarking

5 min

A benchmarking approach that prices intra-group services by comparing internal or external hourly billing rates by role or seniority level.

Transfer pricing in ERP systems

7 min

The configuration, automation and controls used to embed transfer pricing rules directly into an enterprise resource planning system.

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