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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)

Optimized processes and automation in Operational Transfer Pricing (OTP) have become strategic success factors for modern tax functions. Increasing regulatory requirements, data-intensive tax audits, even more complex transactions, growing data volumes, and internal resource constraints are making manual processes increasingly inefficient and prone to risk.

We help you establish your operational transfer pricing processes in a digital, transparent, and audit-ready manner. Through intelligent automation, we ensure consistent data flows, enable continuous margin monitoring, and create the foundation for efficient, traceable compliance processes.

The result: greater efficiency, reduced risks, and a significant reduction in the burden on your internal resources - allowing your tax function to focus on delivering strategic value.

Overview of our key areas of focus 

icon "one"

Effective implementation of transfer pricing models

Maintain full control over margins at all times and ensure arm’s length results based on stable, efficient processes.

OTP as the foundation for efficient 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 conceptually sound but also correctly implemented in day-to-day operations. A robust OTP framework connects the tax, finance, and controlling functions, ensures the consistent application of your TP policies, and enables the early identification of deviations as well as reliable execution of effective adjustment mechanisms.

 

The goal is to strengthen your tax certainty on a sustainable basis while significantly reducing risks such as double taxation or tax audit adjustments. Gain greater transparency over your processes and data, and use targeted automation to manage your administrative workload efficiently and effectively.

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Keep your margins under control at all times.

Margin Monitoring & Segmentation 

We provide powerful solutions for the continuous monitoring of actual vs. target margins and the precise P&L segmentation by transfer pricing relevant functions. This ensures the consistent implementation of transfer pricing policies, increases transparency, and enables deviations to be identified at an early stage, before tax risks arise.

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Secure arm’s length results - efficiently and audit-ready.

TP Adjustments & True-ups

We design and automate transfer pricing adjustments as well as service charge true-ups. Through clearly structured, automated processes, adjustments are traceable, on time, and reliable - even under tight deadlines. At the same time, you create a robust foundation for error-free processes and efficient, audit-ready documentation.

Stable processes instead of manual effort.

Ongoing transfer pricing and service charge calculations

We establish efficient and automated procedures for the regular calculation of transfer prices and intercompany service charges. The result: consistent and reliable calculations, significantly improved data quality, and sustainable, lean, scalable processes - for maximum certainty and transparency in your operational transfer pricing.

Operational Transfer Pricing - A Case Study from WTS Practice

Project Scope

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

A segmented P&L view aligned with the transaction groups defined for transfer pricing purposes was not available from the controlling data. To date, our client had been unable to perform intra-year TP monitoring and adjustments, as manual supplementary calculations were considered too time-consuming and prone to error.

Target operating model

We analyzed the current processes together with the relevant colleagues from the tax and finance functions and developed a coordinated OTP target operating model that combines the tax requirements of the transfer pricing system with the operational needs of Controlling and Accounting. Our client’s objective was to establish an integrated, system-based OTP set-up to achieve:

  • improved transparency regarding margin developments,
  • 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.

Project approach

Based on the target operating model, we defined the conceptual, organizational, and system-related requirements, including the necessary data foundations, conceptual requirements for TP segmentation and price adjustments, as well as the operational framework regarding systems, solutions, and employee resources.

For our client, the following measures were derived:

  • Simplification of OTP processes and standardization of processes between transaction partners and similar transaction types
  • Automated execution of calculations and implementation of additional controls
  • Definition of a streamlined data basis 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 processes using operational guidelines and increased process stability through system-supported workflows

Implementation approach

The development of implementation options started with an analysis of the capabilities within 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 design the data foundations within the posting processes in line with OTP requirements and to enrich the transaction data with TP-specific attributes at the time of posting. Alternatively, attributes for TP segmentation can be modeled in solutions outside of SAP based on the TP-functional concept, with the calculation logic automated subsequently.

Our client’s decision between the available implementation alternatives was based on suitability in light of their specific requirements, the organizational framework, and insights gained from targeted proof-of-concept activities. 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 retention 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 validation mechanisms across all phases of the TP lifecycle. In addition to our documentation and Benchmarking-Solutions, we offer tailored OTP automation solutions for the preparation of transaction matrices, Country-by-Country Reports, and Public CbCRs, reducing the workload for your teams while ensuring sustainable quality improvements:

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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 for the (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 of the reported data across entities.

 

Learn more: Case Studies in Transfer Pricing

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CbCR & Public CbCR

Ready for increased transparency requirements.

With our automation solutions, we support the ongoing fulfillment of your CbCR obligations, as well as the initial set-up 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 support you with data analysis for specific use cases and advise you on the application opportunities 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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