Your study says you are in range.
Does your ledger say the same?
Tax authorities no longer ask for the study. They ask for the evidence. BEPS‑D2V runs your transfer pricing policy as an allocation rule, reconciles it with the general ledger and shows you every month where each entity falls against the range, the CbCR and the Pillar Two minimum.
Intercompany charge flow by jurisdiction
Corporate shared services: 79.9 million allocated to 10 jurisdictions
BEPS is planning: it decides where the group's profit stays
Transfer pricing and Pillar Two are not settled in the books at year-end. They are decided in operations: what each entity buys, who provides the services, where the intangibles sit, how the group is financed and how goods cross the border. BEPS‑D2V™ models those decisions with your data before you make them and measures every month whether they hold. Your advisor designs the strategy; you see its effect on the numbers.
Intangibles and DEMPE
Who develops, enhances, maintains, protects and exploits the brand or the technology decides who earns the royalty. Model each entity's return on what it actually does.
Intercompany financing
Loans, cash pooling and guarantees: rates by credit rating and market curve, and deductible debt capacity by entity, simulated before the agreement is signed.
Foreign trade
The intercompany price is the basis for customs value, import VAT and withholding taxes. See the effect of an adjustment before the goods reach customs.
Value chain
Limited-risk distributor, contract manufacturer, service center: compare the margin and effective tax rate of each operating model by country.
Pillar Two by scenario
Project the effective tax rate by jurisdiction during the year and decide in time whether you qualify for the safe harbour or will owe top-up tax.
Intragroup services
Every charge with its driver, its deliverable and its journal entry, month by month. That is the substance Mexico's Tax Code and Colombia's Council of State now require.
The job is no longer having the study. It is proving the price.
The head of tax has to show, entity by entity and year by year, that the agreed price actually hit the ledger, falls within range, ties to the CbCR, the Local File and the information return, and does not trigger top-up tax. The annual study describes a year that has already closed; it does not govern the price while it happens.
The study arrives late
The adjustment is found at year-end, when fixing it already costs VAT, withholding and customs.
Segmentation does not reach the cost
In BANACOL (Colombia's Council of State, 2024), a business-line segmentation failed because it proved neither functional autonomy nor allocated costs.
Every report has its own number
CbCR, Local File, information returns and Pillar Two are built separately, and nobody reconciles them to the ledger.
The firms that document transfer pricing agree: the challenge is data and execution
The study is still essential. What changed is where the defense is lost: in fragmented systems, manual adjustments and figures that do not tie across reports. This is what PwC, Deloitte and the OECD publish.
34% of tax executives rank the lack of a coherent data strategy among their top three barriers. Fragmented systems and manual adjustments slow the close, and true-ups arrive at quarter- or year-end.
AI in transfer pricing →Tax authorities cross-check the Local File and information returns against the company's public information, and every discrepancy gets flagged. The CbCR is reviewed by comparing patterns across jurisdictions.
AI in transfer pricing →Manual processes, fragmented systems and inconsistent data sources make it harder to show the policy was applied as designed. Monitoring during the year avoids significant year-end true-ups.
Unlock operational TP →Panama passed Law 526 of 2026: an economic substance regime for foreign-source passive income. PwC describes transfer pricing as a pillar of tax governance under growing regional scrutiny.
PwC Interaméricas note (Spanish) →The transitional CbCR safe harbour was extended to fiscal years beginning before Dec 31, 2027, at 17%. From 2027 a permanent simplified ETR safe harbour at 15% applies, calculated from financial accounting data.
PwC Austria (German) →It takes the data from the ERP, runs the policy as a rule, reconciles with the ledger and feeds the Local File, CbCR and Pillar Two from the same number. Your advisor keeps the technical judgment.
Try the demo →Ten questions your ledger can answer
They are the same questions Mexico's SAT, Colombia's DIAN and Spain's AEAT ask. If you cannot answer them in numbers today, that is your exposure.
Your result is within range, but how far from the median?
Are your comparables three years old and from a different business reality?
Has anyone reconciled your study with your ledger?
Is the year-end adjustment found when it can no longer be fixed at no cost?
Does your functional analysis describe a company that no longer exists?
Does your CbCR say one thing and your Local File another?
Do the invoice, the contract and the study tell three stories?
Is your ETR one point away from losing the safe harbour, for good?
Does your segmentation hold up when they ask for the cost behind it?
Is the person who prepared your tax position the one reviewing it? Separate who produces from who reviews.
The policy is the calculation, and the calculation leaves a trail
The allocation rule in Oracle EPCM runs the policy. The study describes it. Every figure that reaches the CbCR or Pillar Two can be drilled down to its rule and source account.
Ledger
Costs by entity, cost center and account, from the ERP.
EPCM rule
The policy's pools, drivers and markup, run as rules.
Segmented P&L
Profit by entity before and after charges.
Range and true-up
Actual markup against quartiles and median; proposed adjustment before the close.
CbCR · Local File · Pillar Two
A single cube feeds the reports, with the reconciliation in view.
Move the levers and see what your advisor is not measuring
FY24 figures from our BEPS‑D2V demo: nine entities, a shared services pool and its markup policy. Sample data, not client data.
Band: interquartile range Q1 4.5% – Q3 9.1% · line: median 6.8% · dot: markup. Out of range, the adjustment goes to the median (Mexico, Income Tax Law art. 180). Green: in range above the median · orange: in range below the median · red: out of range.
Simplified ETR from the CbCR. A jurisdiction that fails the transitional safe harbour in one year cannot use it again: “once out, always out”. Gibraltar already requires a full GloBE calculation in the demo.
| Entity | CbCR revenue | FS revenue | Difference | CbCR PBT | FS PBT | Difference |
|---|
The CbCR comes from the same cube as the segmented P&L: every difference is flagged before filing. Reporting currency, FY24.
| Entity | Intercompany charges | Markup cost | Allocated charges | Weight |
|---|
USA is the provider: it earns 2.77 million in markup income from the affiliates. Reporting currency, FY24.
Test what you already bought, with the tax authority's logic
Ten tests on your study, your ledger and your CbCR: price precision, true-up, reconciliation, comparables, substance, cost base, contracts, VAT and customs effects, OECD risk-indicator radar and Pillar Two. The result is an entity-by-test heat map with the exposure in currency.
Flash
A quick read with the data you already have: distance to the median by entity, OECD risk-indicator radar and safe harbour tests.
Deliverable: a traffic light by jurisdiction and three prioritized findings.
Nominal fee, credited toward the AssessmentAssessment
All ten tests for the in-scope entities, with exposure in currency and operating maturity from 1 to 5.
Deliverable: an entity × test heat map and a “low risk / needs attention / high risk” rating.
Fixed fee per block of entitiesBlueprint
The BEPS‑D2V design to close the gaps: rules, dimensions, close calendar and reporting packages.
Deliverable: architecture, implementation plan and business case.
Credited against the implementationPrefer to start on your own? Take the transfer pricing maturity assessment → 42 practices, about 10 minutes, with your profile as a PDF (in Spanish).
What changes when the price is proven every month
Three groups, three industries, outside banking. Same method: the policy runs as a rule in Oracle EPCM and every figure drills down to its account.
Royalties and regional services, country by country
Each country pays royalties and regional service fees. The study came out fine at year-end, but the margin moved during the year and the adjustment arrived when it already cost withholding and VAT.
8 in 10 countries in range before the close, and a year-end true‑up cut to less than half.
Brands, intangibles and effective tax rate across dozens of countries
The brands sit in a few entities and the value-creating functions are spread out. With subsidiaries in Pillar Two jurisdictions, the group needed the effective tax rate by country before the close.
Return adjusted in 1 in 4 entities, and effective tax rate alerts at least one quarter before the close.
Three fiscal years that did not tie out
Plants under a contract manufacturing (maquila) regime with regional incentives that lower local profit, a parent subject to Pillar Two, and advisor reports that did not tie to the books for three fiscal years.
More than 9 in 10 differences explained down to the account across three fiscal years, and local GloBE effective tax rate projected by year.
We design the model. Your advisor keeps the judgment and the relationship.
In all three cases we acted as the design authority for the Oracle EPCM model, alongside the transfer pricing firm and the implementation team. The firm sets the policy and defends it; the implementer builds; we design the rules that run it and hand it over documented. The same principal qualifies the opportunity and designs the model.
Real cases. For confidentiality we omit names, brands and figures that could identify the clients.
Your advisor keeps the technical judgment. You keep the number.
The comparables search, the functional analysis and the defense before the authority remain with your TP specialist. BEPS‑D2V closes the gap between that judgment and the accounting number, on the EPM platform your team already runs.
The study explains the price. The ledger proves it.
Asher & Company: EPM and profitability specialists, backed by the PwC Strategic Finance Center of Excellence.
A Flash in one week, with the data you already have
Tell us where you operate and we will tell you what we need. A principal replies within one business day.