The success of a transfer pricing system depends largely on its consistent operational implementation – known as Operational Transfer Pricing (OTP). OTP is a key factor in achieving sustainable tax benefits and ensuring the system can be defended during tax audits both at home and abroad. Modern technologies help to ensure the consistency, transparency and traceability of the transfer prices applied.

Embedding transfer pricing in day-to-day operations

An effective OTP system embeds the transfer pricing concept throughout the entire organisation, its operational processes and the underlying data. Technology enables a standardised and scalable representation of the transfer pricing logic across end-to-end processes.

Technology as an enabler for OTP

OTP software supports companies in setting transfer prices at the start of the year based on forecasts specifically optimised for OTP. It also enables the continuous monitoring of target margins through automated TP segmentation of financial data. This allows deviations to be identified at an early stage and transfer price adjustments to be carried out in accordance with system requirements, both during the year and at year-end.

Furthermore, data relevant to transfer pricing documentation can be processed automatically, and key information – such as transaction matrices – can be generated efficiently.

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KI kann Transfer-Pricing-Teams bereits bei mehreren Aufgaben unterstützen. Entscheidend ist, ihre Stärken und Grenzen richtig einzuschätzen.

GenAI im Transfer Pricing: 5 konkrete Use Cases für Unternehmen

Our approach

A holistic OTP approach combines tax objectives, operational processes and technological solutions into an integrated end-to-end model.

The KPMG Centre of Excellence for Transfer Pricing Innovation & Technology supports companies throughout the entire process, from strategic design and implementation to the continuous optimisation of their transfer pricing systems. Our interdisciplinary team combines expertise in transfer pricing, controlling and finance, as well as IT, and works with you to develop technology-enabled solutions for transparent and future-proof transfer pricing management.

TP Technology
OTP Business Case

In an increasingly data-driven tax environment, it is no longer sufficient to define transfer prices merely in conceptual terms. They must be calculated transparently, applied consistently, monitored continuously and adjusted where necessary. Modern technology in the field of transfer pricing (TP) creates transparency regarding margins and intra-group transactions and enables the automated identification of necessary price adjustments. At the same time, the transfer pricing concept is integrated directly into operational processes.

Intelligently linking data and processes

Operational Transfer Pricing (OTP) requires close collaboration between Finance, Tax, Controlling and IT. TP Technology supports this integration by consolidating data from various source systems, providing automated calculation logic and identifying deviations from target margins at an early stage. This enables risks to be managed, manual processes to be reduced and necessary adjustments to be implemented efficiently – even within complex international corporate structures.

Specialised TP Technology transforms OTP from a purely compliance-based task into an actively manageable process. Companies can efficiently meet regulatory requirements, confidently navigate tax audits and make decisions based on consistent data. Transfer pricing management is thus permanently and efficiently embedded within the organisation.

Our expertise

OTP Software Selection

Choosing the right OTP software is the foundation of effective and sustainable operational transfer pricing. We will work with you to analyse your requirements and assess whether a platform solution (e.g. SAP PaPM or Microsoft Power Platform) or specialised off-the-shelf software such as EXA OTP or AIBIDIA Operational TP is the most suitable option.
OTP Software Implementation

The implementation of the OTP software involves integrating the transfer pricing concept into the system, defining clear roles and responsibilities, and overseeing a structured and smooth roll-out.
OTP Managed Service

The OTP Managed Service handles the day-to-day running of your OTP processes, freeing up capacity for your core business.
Process automation using low-code/no-code technologies

Using low-code/no-code technologies, bespoke automation solutions can be developed for specific OTP data areas, such as TP segmentations or cost allocation processes.
SAP S/4HANA

When implementing SAP S/4HANA, we ensure that transfer pricing requirements are taken into account at an early stage of the project and integrated into the system.
The use of AI for transfer pricing

Suitable AI use cases in the transfer pricing field are identified and tested as part of a proof of value to assess their practical benefits and potential within the company.

A robust business case for Operational Transfer Pricing (OTP) forms the basis for well-informed management decisions and the successful implementation of an OTP software solution. It presents the strategic and operational benefits of an OTP solution in a structured and transparent manner, thereby enabling management to make informed decisions.

The business case quantifies financial impacts, identifies efficiency potential and assesses risks arising from the interplay between organisation, processes and technology. It also provides clarity on investment requirements, implementation costs and the tax and regulatory benefits.

The basis for informed decisions

The OTP Business Case thus fosters strong leadership buy-in, enables prioritised resource allocation and lays the groundwork for a structured and technology-enabled implementation of operational transfer pricing.