Transforming perspectives through operational transfer pricing
International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX
Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Transforming perspectives through operational transfer pricing

The COVID-19 pandemic has continued to put tax at the forefront

Transfer pricing perfection may be out of reach but automation can bring you closer. Dianne Berry, Meenakshi Iyer, Jack O’Meara, Kirsty Rockall and Tim Wong of KPMG member firms in the UK, US and Netherlands look at how operational transfer pricing (OTP) is changing business for the better.

Setting inter-company pricing policies is challenging but achievable for most organisations. It's a much bigger task to align these policies with your transfer pricing processes and controls and implement. Transfer pricing perfection is impossible in today's environment, and it's getting even harder as business models grow more complex and demands for tax transparency intensify.

Operational transfer pricing (OTP) can help. OTP is the management of transfer pricing data, processes and governance using technology. An effective OTP programme aligns transfer pricing requirements with commercial goals, thereby promoting compliance, reducing complexity, delivering strategic insights and driving better business decisions.

In this article, we explore why OTP is attracting renewed attention. We also dispel some common misconceptions about OTP and highlight its potential benefits.

OTP back in the spotlight

Historically, multinational organisations upgraded their finance systems by investing in enterprise resource planning (ERP) systems. However, these investments tended to focus on managing the business overall, rather than specific legal entities, and the alignment of the commercial, finance and tax functions were often not considered.

Financial system readiness is a key tenet of OTP. As organisations implemented their transfer pricing policies, ERP systems were found to be less effective for managing the tax and transfer pricing processes. Organisations took to using offline manual processes or external tools (e.g. spreadsheets) to set, test and monitor their inter-company price setting and accounting.

Nevertheless, organisations could accept this state of affairs. The prevailing tax environment gave them ample time after year-end to calculate, adjust and re-calculate their intra-company prices and manage the impact on their entities' bottom lines.

Today, however, tax authorities' data requests and digital capabilities are leaping ahead of many businesses real-time reporting and analysis – and the luxury of time has vanished.

Perhaps the biggest reason OTP is back in the spotlight is the regulatory burden put on transfer pricing by the OECD's project to address base erosion and profit shifting (BEPS). As a result of the OECD's BEPS recommendations, tax authorities can access tremendous amounts of data from, among other things, detailed digital (i.e. real-time) tax filing requirements, automatic exchange of information and country-by-country reports.

Political pressure from governments across the globe also means that each tax authority has a vested interest in transfer pricing and making sure that they get their 'fair share' of profits.

These developments make it important to have a consistent narrative for compliance purposes that covers both policies and data. As tax authorities sharpen their focus on data integrity and transfer pricing governance, they expect taxpayers to be able to show they have adequate processes and controls in place to ensure transfer pricing outcomes at the legal entity level match expectations. Organisations are being assessed on whether their transfer pricing policies match what's happening on the ground. Tax authorities are also looking at whether companies' year-end results are in line with what they projected when the year began and, if not, whether they have a good business reason for any true-up adjustments.

Another reason OTP is gaining attention is that transfer pricing errors are increasingly having more significant financial statement impacts. For example, US tax reform requires global companies to manage data that is precise enough to produce entity-level results that may require further segmentation (i.e. for computing foreign tax credits and global intangible low-taxed income (GILTI)). US tax reform has also spurred substantial restructuring activity, creating more transactions and more OTP obligations.

So, in today's climate, the need to align business with compliance is crucial. Transfer pricing requires input from and alignment between various stakeholders within the company, and automation can help achieve this alignment. Technology solutions are also being used to ingest, decipher and analyse large amounts of data, enabling tax and finance to successfully manage stakeholders' concerns.

Dispelling OTP myths

OTP means different things to different people. The OTP process can differ by type of transaction and there are some misconceptions about what OTP is all about. Below we seek to dispel some of these myths and highlight how an effective OTP process is critical for effective transfer pricing management in today's environment.

'OTP only focuses on the end-to-end process'

OTP certainly focuses on the end-to-end process, following the numbers from forecasting through to financial statement reporting. This is the recurring aspect of the transfer pricing lifecycle and automating parts of this process is often seen as the bedrock of OTP.

However, OTP also goes beyond the end-to-end process to cover standalone projects such as the automation of management service allocation charges or profit split calculations.

'OTP involves large finance transformations, so it's not for us'

It's true that OTP is important for aligning finance, enterprise and tax on projects such as moving ERP systems to the cloud or consolidating multiple systems into one. However, OTP is also relevant for smaller projects, like making a manual spreadsheet process a little less manual. This means reviewing internal processes and locking down elements that may be calculated in spreadsheets to prevent transposition and other errors or eliminate time spent checking and double-checking calculations.

'OTP always includes automation'

Technology should be a key component but not an integral one. People are also key to OTP. Processes only work smoothly when people fully understand their roles and responsibilities, including those of people outside of the tax or transfer pricing teams.

For example, the transfer pricing team may receive market prices from the sales department and forecasts from financial planning and analysis department to set a transfer price for products that move through a complex intra-company supply chain. At the same time, the accounting team needs to ensure the prices for each product or product group are applied properly to generate the correct journal entries for posting to the ERP system.

Clear accountabilities can significantly reduce the amount of time transfer pricing teams spend simply finding and mapping the correct data. It's also important to revisit and reinforce these accountabilities over time to ensure transfer pricing practices continue to reflect the model. For example, a change in personnel could lead to errors in journal entries that may not become apparent until years later during a tax audit.

'Automation means I won't be needed anymore'

As with other aspects of digitalisation, transfer pricing technology is moving from the lower end of the spectrum, where people follow processes supported by technology, to the higher end, where technology follows processes supported by people.

Some people think technology is capable of full automation that eliminates the need for people. This may happen in the future, but existing technology primarily supports and augments repetitive and routine manual transfer pricing activities that people remain responsible for, freeing up their time for more value-adding work.

'Why use OTP when it's easier and cheaper to use a ready-made tool?'

While this might have been true in the past, OTP technology and tools have evolved to meet increasing data demands with quicker, more flexible, and more efficient deployment. Solutions are available that can improve the efficiency of transfer pricing calculations by integrating the data that comes directly from company's various processes for, for example, financial statement journal entry, monitoring and invoicing.

An effective OTP process depends on an organisation's business, industry and systems. These are unique from entity to entity, so the best solutions are tailor-made. They do not have to break the bank, however, especially for organisations that are automating an aspect of their transfer pricing process rather than installing an automated end-to-end solution. Specific OTP software solutions are available that can enhance the implementation of technology due to standard functionalities and customisable reporting capabilities.

Whatever technology is selected, success requires in-depth consideration of the process and the people who sustain it.

The key takeaways

A transfer pricing process review and implementation of technology can yield substantial returns in these areas:

  • Savings and efficiency gains: OTP processes offer improvements and technology implementations that can be deployed quickly and reduce process turnarounds and cycles, thereby freeing resources for other activities;

  • Managing risk: Reducing manual activities through standardised transfer pricing solutions mitigates risks of human error;

  • Better process controls: OTP processes can be outfitted with control solutions that are traceable, auditable and robust, and can be followed when transfer pricing team members change;

  • Stronger collaboration: Clarifying roles and responsible among tax, finance and other stakeholders can enhance coordination and collaboration across functions;

  • Improved processes: The augmented review that comes with OTP stands to significantly improve the accuracy and reliability of transfer pricing processes;

  • Scalability: OTP solutions can be built through flexible, modular designs that can be scaled up as needed; and

  • Driving insight: A common data model or data visualisation can provide a powerful platform for both reporting and advanced analytics.

Before embarking on an OTP project, remember to be realistic. Automating a process or managing risk is not as simple as clicking a button. You must ensure that you fully understand the issue you are trying to solve and win crucial buy-in and support from business leadership. Doing so will make it much more likely that your project will succeed.

© 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

Dianne Berry



Meijburg & Co, KPMG Netherlands

Tel: +088 90 93226

Dianne Berry is a director in the transfer pricing practice of KPMG Meijburg & Co (Netherlands), based in Eindhoven.

She has around 15 years of experience in assisting mid-size to large companies with diverse matters including designing and implementing transfer pricing policies, documentation and related analyses and dispute resolution. She also regularly works on matters concerning international and Dutch corporate tax.

Jack O’Meara



KPMG in the US

Tel: +1 415 963 5191

Jack O'Meara is a principal in the Washington national tax economic and valuation services practice of KPMG in the US, based in San Francisco.

He has more than 20 years of experience advising clients on transfer pricing and economic matters, and has particular expertise in working with the technology industry. He has extensive experience providing clients with valuations and economic analyses to support global tax planning and business transformation strategies.

Tim Wong



KPMG in the US

Tel: +1 408 367 2202

Tim Wong is a partner in the tax ignition practice of KPMG in the US, based in San Francisco.

He leads the tax data and analytics team in KPMG in the US's ignition centre, which is focused on developing innovative solutions to automate, model and analyse complex tax computations with large data volumes. He has more than 20 years of experience in focusing on process improvement and technology implementation for the tax function.

Kirsty Rockall



KPMG in the UK

Tel: +44 20 73113473

Kirsty Rockall is a partner in the transfer pricing practice of KPMG in the UK, based in London.

She has more than 20 years of transfer pricing experience and leads the London region and south transfer pricing teams. Kirsty is KPMG's European lead for operational transfer pricing and helps clients to design and implement new processes, systems and ways of working that can transform how they approach transfer pricing.

Meenakshi Iyer



KPMG in the UK

Tel: +44 20 76948674

Meenakshi Iyer is a director in the transfer pricing practice of KPMG in the UK, based in London.

She has more than 15 years of experience designing, documenting, implementing and defending transfer pricing models for large multinationals. She has experience of designing efficient operational processes and helping clients in selecting the most appropriate automation/technology solution to meet their transfer pricing requirements. She has experience across a range of industries but has a particular focus on clients in the pharmaceutical and technology, media and telecommunications sectors.

more across site & bottom lb ros

More from across our site

The 61-year-old has run the firm’s UK business since 2020
The report, which again demanded PwC release more information related to the scandal, “did not go far enough”, Australian Greens Senator Barbara Pocock told ITR
Resources needed to manage new compliance and financial reporting requirements will be significant, BDO also said
Interested parties may submit their comments on proposed bills and the subsidiary legislation by July 5
The Australian government has run roughshod over professional tax bodies with untested reporting obligations to please a mob baying for PwC’s blood, writes Tom Ravlic
Technical excellence is paramount for clients looking to hire new advisers, according to a survey of nearly 29,000 corporate counsel
The EU nation currently has a headline rate of 25%; in other news, DLA Piper and RSM UK have strengthened their tax teams
Labour's plans for closing the tax gap suggest that taxpayers may face an increasingly aggressive HMRC
Rosenberg, Siemens' New York-based chief tax counsel, tells ITR about Ben Affleck comparisons, welcoming challenges from US tax authorities and what makes tax cool
The settlement means the IRS will receive $200 million from the defunct crypto exchange’s bankruptcy, a fraction of the claim value
Gift this article