TPMPWhat's inside
One platform. Modules for all your TP needs.
Three modules, in the order the work actually happens. Design decides, Implementation executes, Documentation records. Each one reads from the same structured data, which is why the third stops being a separate project.
The thinking
Design
Where a transaction is assessed and the method is decided, before anything is documented.
- TP planning
- TP risk
- Functional analysis
- Value chain analysis
- International tax considerations
- VAT considerations
- Impact on financial statements
The execution
Implementation, OTP
Operational transfer pricing. Where the decision becomes live operating models, agreements, benchmarks and accounting data, automatically.
- Intercompany agreements
- Intercompany calculations
- Filing of intercompany schedules
- Thin capitalisation analysis
Benchmarking studies
- CUP (royalties)
- CUP (services)
- CUP (financing)
- TNMM
The record
Documentation
Built from the same structured data the rest of the platform runs on. Not re-gathered each year. Available in hours, not months.
- Master File
- Local File
- TP Policy
- CbCR
- Business restructuring memos
Why the order matters
Most problems are a sequencing problem.
A benchmark commissioned before the functional analysis is finished tests the wrong thing. An agreement drafted after the invoices have gone out papers over what already happened. A Local File written from scratch in month eleven describes a policy nobody has been following.
Running the three modules on one data set forces the order, and the order is most of the value.
The chain, in sequence
What each stage hands to the next
- Design hands over a method, a policy and a set of terms, as data rather than as a memo.
- Implementation reads those terms and generates the agreement, the calculation and the benchmark that support them.
- Documentation reads all of it and assembles the file, citing the work that was actually done.