Related-party transaction mapping
Every intercompany flow identified from the ledger and matched to a policy, an agreement and a counterparty.
TP24
Transfer pricing intelligence beyond documentation.
A technology-enabled transfer pricing platform for managing related-party transactions, arm's-length analysis, compliance documentation and audit readiness — from the same data all year, not a file assembled once a year.
DomainTransfer pricing
AnchorOECD Guidelines & local rules
ScopeTransaction to local file
AI roleMapping, drafting, review
Benchmark sourcesto be confirmed
The problem
The documentation is annual. The exposure is continuous.
Intercompany flows change through the year while the local file describes the year that ended. Functional analysis lives in interview notes, benchmarks in a consultant's spreadsheet, and the connection between the policy and what the ledger actually did is rebuilt from memory each cycle.
TP24 keeps the transaction map, the analysis and the evidence in one place, so documentation is a report from the system rather than a project.
Who it is for
Group tax functions
Managing policy, pricing and documentation across multiple jurisdictions.
Transfer pricing specialists
In-house or in practice, running analysis and defending it under audit.
Local finance teams
Meeting country filing duties without rebuilding group analysis locally.
Advisory firms
Serving a portfolio of clients on one consistent methodology.
Core capabilities
01
02
Functional and risk analysis
Functions, assets and risks captured as structured data per entity — comparable across years and reusable.
03
Method selection
Method choice recorded with its reasoning and the rejected alternatives, ready for a tax authority to read.
04
Benchmarking workflow
Search strategy, screening decisions and the resulting range preserved as evidence, not just the final number.
05
Local file generation
Documentation assembled from the live data model, with local content requirements handled per jurisdiction.
06
Audit trail and compliance management
Deadlines, filings and every analytical decision tracked with the version of the data behind them.
How the platform works
01
Map
Entities, agreements and intercompany flows loaded and linked.
02
Characterise
Functional and risk profile captured per entity and transaction.
03
Price
Method applied, benchmarks run, arm's-length range set.
04
Monitor
Actual results tracked against the range through the year.
05
Document
Local file and defence pack generated from the same source.
Example workflow
A new intra-group service arrangement
Illustrative sequence, not a client engagement.
01
A new management-service charge appears in the ledger and is flagged as unmapped.
02
The agreement is attached; AI drafts the transaction description for the specialist to correct.
03
Functional analysis identifies the service provider as routine; TNMM is selected and the reasoning recorded.
04
A benchmarking set is screened and the arm's-length range fixed, with every rejection logged.
05
Quarterly monitoring shows the tested margin drifting below the range; an adjustment is proposed early.
06
At year end the local file is generated with the analysis, the range and the monitoring history attached.
Outcomes
Documentation as output
The local file is generated, not assembled from scratch each year.
No year-end surprises
Margins monitored against the range while adjustment is still cheap.
Consistent methodology
One approach across entities and years, whoever does the work.
Audit readiness
Questions answered from the record rather than from recollection.
Cycle-time and cost comparisons to be added once measured with client data
Data security and auditability
Entity-level access control for groups where local teams must not see the whole picture.
Versioned analysis: the file as filed can always be reproduced.
Agreements, benchmarks and workings stored with the conclusion they support.
Change history on every judgment, with author and date.
Certifications and independent assurance to be confirmed
Integration
ERP and consolidation systems for intercompany balances and segment results.
Contract and document repositories for agreements and evidence.
Commercial benchmarking databases through the search workflow.
Shared entity and financial data with GMT24 where both platforms are in use.
Named system connectors to be confirmed
Bring your transfer pricing file into the system that produced it.
We will map one intercompany transaction end to end with your own data and show the documentation that comes out.
Request a Demonstration