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Operational Transfer Pricing
Home Services Tax Operational Transfer Pricing
OTP
IMPLEMENTATION TRANSFER PRICING MODELS
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Operational Transfer Pricing (OTP)

Optimal processes and automation in Operational Transfer Pricing (OTP) are now strategic success factors for modern tax departments. Increasing regulatory requirements, data-intensive tax audits, increasingly complex transactions, growing volumes of data, and internal resource constraints are making manual processes increasingly inefficient and risky.

We help you set up your operational transfer pricing processes in a way that is digital, transparent, and audit-ready. Through intelligent automation, we ensure consistent data flows, enable continuous margin monitoring, and lay the groundwork for efficient, traceable compliance processes.

The result: greater efficiency, reduced risks, and a noticeable reduction in the burden on your internal resources - so your tax function can focus on strategic value creation.

An overview of our key areas of focus 

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Effective implementation of transfer pricing models

Maintain control over margins at all times and ensure results that comply with arm’s-length principles based on stable, efficient processes.

OTP as the foundation for efficent TP compliance

Transaction matrix and CbCR / Public CbCR with automated analyses at the click of a button.

Special Topics in Operational Transfer Pricing

Support with data analysis, technology consulting, AI, and coaching.

Effective Implementation of Transfer Pricing Models

OTP is essential for ensuring that your transfer pricing is not only structurally sound but also properly implemented in day-to-day operations. A robust OTP setup integrates tax, finance, and controlling functions, ensures that your transfer pricing complies with regulations, and enables you to identify deviations early on and reliably implement effective adjustment mechanisms.

 

The goal is to strengthen your tax security in the long term and significantly reduce risks such as double taxation or tax audit adjustments. Gain transparency into your processes and data - and use targeted automation to manage your administrative workload efficiently and in a controlled manner.

 

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Keep your margins under control at all times.

Margin Control & Segmentation 

We offer powerful solutions for the ongoing monitoring of actual and target margins and the precise segmentation of business units in the context of transfer pricing-relevant transactions. This ensures consistent implementation of transfer pricing guidelines, increases transparency, and identifies deviations early on, before tax risks arise.

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Ensure results that are consistent with industry benchmarks - efficiently and in a manner that stands up to audit scrutiny.

TP Adjustments & True-ups

We design and automate transfer pricing adjustments and service charge true-ups. Thanks to clearly structured, automated processes, adjustments are traceable, timely, and reliable, even under tight deadlines. At the same time, you create a solid foundation for error-free processes and efficient, audit-proof documentation.

Reliable processes instead of manual effort.

Ongoing transfer pricing and service charge calculations

We establish efficient and automated processes for the regular calculation of transfer prices and intra-group service charges. The result: consistent and reliable calculations, significantly improved data quality, and permanently streamlined, scalable processes - ensuring maximum certainty and transparency for your operational transfer pricing.

Operational Transfer Pricing - A Case Study from WTS Practice

Project Scope

We assisted our client in implementing effective processes for proactive operational transfer pricing management.

A segmented income statement that provided a view of the transaction groups defined for transfer pricing was not available from the controlling data. Until now, our client had been unable to perform interim transfer pricing reviews and adjustments because manual secondary cost calculations were considered too time-consuming and prone to errors.

Target vision

We reviewed the current processes together with the relevant colleagues from the tax and finance departments and developed a coordinated OTP target model that combines tax law requirements for the transfer pricing system with the operational needs of Controlling and Accounting. Our client set the goal of establishing an integrated, system-based OTP setup for a

  • improved transparency regarding margin trends,
  • early identification of potential risk areas and deviations between actual and planned transfer prices,
  • proactive identification of regular adjustment needs, and
  • reduction of administrative effort through automated execution.

Approach

Based on the target vision, we define the conceptual, organizational, and system-related requirements, including the necessary data foundations, technical requirements for TP segmentation and price adjustments, as well as the operational framework regarding systems, solutions, and human resources.

The following measures were derived from this for our client:

  • Simplification of OTP processes and standardization of workflows between transaction partners / similar transaction types
  • Automated execution of calculations and introduction of additional controls
  • Definition of the data foundation and enrichment of the data in the ERP system through additional attributes
  • Strengthening of governance structures and reduction of unsystematic exceptions
  • Clear communication of target workflows using operational guidelines and increased process stability through system-supported workflows

Procedure

The development of implementation options began by examining the capabilities of the existing ERP system and the potential benefits offered by external solutions, such as OTP-specific software or BI/low-code automation tools.

SAP S/4 HANA implementations provide a good opportunity to structure the data foundations within the posting processes in accordance with OTP requirements and to enrich the posting data with TP-specific characteristics right at the time of posting. Alternatively, the TP characteristics for TP segmentation can be modeled in solutions outside of SAP based on the business concept, and calculation logic can be automated subsequently.

Our client’s decision between the possible alternatives for implementation was based on suitability in light of their specific requirements, the organizational framework, and their experiences from targeted proof-of-concepts. The implementation of the solution was supported by focused project management and a well-thought-out change management concept.

OTP as the foundation for efficient TP compliance

Your OTP processes form the foundation for efficient transfer pricing compliance, as they provide the data basis for your transfer pricing documentation. Optimized data preparation and security enable significant efficiency gains and improvements in quality during the documentation phase.

Our automation strategy therefore does not view OTP and TP compliance in isolation, but rather as an integrated platform that seamlessly connects data, processes, and verification mechanisms across all phases of the TP lifecycle. In addition to our documentation and Benchmarking-Solution, we offer tailored OTP automation solutions for the creation of transaction matrices, country-by-country reports, and public CbCRs, which relieve your teams and ensure quality in the long term:

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Transaction Matrix

Transaction matrix at the click of a button.

We automate the analysis and processing of your transaction data and present it in a structured format within an (advanced) transaction matrix. Individual transactions are automatically grouped into transaction groups based on defined criteria, in accordance with your transfer pricing system. Integrated validation mechanisms ensure data quality and consistency across the reported data from the various companies.

 

Learn more: Case Studies in Transfer Pricing

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CbCR & public CbCR

Ready to meet increased transparency requirements.

With our automation solutions, we support the ongoing fulfillment of your CbCR obligations, as well as the initial implementation and efficient annual execution of the new public CbCR requirements. Our EU Public CbCR Risk Analysis Dashboard provides immediate insights through clear and meaningful visualizations.

 

Learn more: Country-by-Country Reporting

Special Topics in Operational Transfer Pricing

In addition, our experts provide support with data analysis for specific use cases and advise you on the potential applications of AI and TP technology.

Well-versed in tax audits.
(Big) Data Analysis for Tax Audits
We prepare your financial and transaction data specifically for tax audits and identify potential anomalies early on. Using state-of-the-art analytical tools, we automatically analyze large volumes of data and strengthen your position with robust, data-driven arguments.
Greater efficiency through AI.
Innovation & AI
We identify specific use cases for applying artificial intelligence and automation to your tax and financial processes and support you through their implementation. This significantly reduces the workload on your teams, boosts efficiency, and enhances transparency and quality in your day-to-day operations.
Ready for digital TP solutions.
Technology consulting and coaching
We advise you on the selection, implementation, and integration of suitable TP technology solutions into your existing system landscape and team workflows. Through hands-on coaching, we ensure that your employees use new tools confidently, efficiently, and sustainably.

Your contact for Operational Transfer Pricing

bild may-miriam

Miriam May

Director Transfer Pricing

Nürnberg

Miriam.May@wts.de
to profile
bild Hanken-Joerg

Jörg Hanken

Partner Tax

München

+491602927060
Joerg.Hanken@wts.de
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David van Leuven

Director Digital

Düsseldorf

+49211957828537
David.vanLeuven@wts.de
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Hubert Bauer

Partner Tax

München

+49 (0) 151 431 69532
hubert.bauer@wts.de
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Florian Gimmler

Partner Tax

Frankfurt

+49 15122464342
florian.gimmler@wts.de
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Services
Transfer Pricing
Today more than ever, transfer pricing is a critical factor and the key to sustainable business success in the face of international competition. At WTS, we are committed to a comprehensive, forward-looking approach to transfer pricing that goes far beyond mere compliance.
Learn more
Services
CBCR Reporting
Whether you are currently working on implementing the traditional non-public CbCR (OECD), wish to take advantage of the simplification rules regarding the minimum tax based on a qualified CbCR, or are already considering the upcoming public CbCR (EU/EEA)—WTS is here to provide you with comprehensive support.
Learn more

Other topics that might interest you

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