Glossary
Transfer pricing terms, explained for finance teams
150 definitions covering the concepts that actually come up when a group prices its intercompany transactions: methods and benchmarking, financing and cash pooling, reconciliation, VAT and reporting. Each entry explains the term and what it means for the numbers you have to book and defend.
Fundamentals
25 terms
- Arm's Length Principle
- Benchmarking Study
- IRC Section 482
- OECD Transfer Pricing Guidelines
- Operational Transfer Pricing
- Transfer Price
- Transfer Pricing
- Transfer Pricing Adjustment
- Transfer Pricing Agreement
- Transfer Pricing Audit
- Transfer Pricing Compliance
- Transfer Pricing Definition
- Transfer Pricing Documentation
- Transfer Pricing Methods Overview
- Transfer Pricing Penalties
- Transfer Pricing Policy
- Transfer Pricing Risk Assessment
- Transfer Pricing Rules
- Transfer Pricing Services
- Transfer Pricing SME Exemption
- Transfer Pricing Software
- Transfer Pricing Study
- Transfer Pricing Tax
- Transfer Pricing UK
- What Is Transfer Pricing
Methods & benchmarking
25 terms
- Arm's Length Range
- Benchmarking Database
- Berry Ratio
- Best Method Rule
- Comparability Adjustment
- Comparability Analysis
- Comparable Companies
- Comparable Uncontrolled Price Method
- Cost Plus Method
- Full Cost Mark-Up
- Functional Analysis
- Interquartile Range
- Mark-Up on Total Costs
- Multiple Year Data
- One-Sided Method
- Operating Margin
- Profit Level Indicator
- Profit Split Method
- Resale Price Method
- Return on Assets
- Safe Harbour
- Secret Comparables
- Tested Party
- Transactional Net Margin Method
- Working Capital Adjustment
Financing & treasury
25 terms
- Arm's length interest rate
- Back-to-back loan
- Cash pool interest allocation
- Cash pool leader remuneration
- Cash pooling
- Credit rating for transfer pricing
- Debt capacity analysis
- Deposit rate benchmarking
- Funds transfer pricing
- Group treasury policy
- Implicit group support
- Intercompany factoring
- Intercompany guarantee fee
- Intercompany hedging
- Intercompany loan
- Intercompany receivables interest
- Interest limitation rules
- Interest rate benchmarking database
- Loan benchmarking
- Notional cash pooling
- OECD Chapter X financial transactions
- Physical cash pooling
- Thin capitalisation
- Treasury transfer pricing
- Working capital adjustment
Operations & compliance
25 terms
- Advance pricing agreement
- BEPS
- Cost allocation keys
- Country-by-country reporting
- Hourly rate benchmarking
- Intercompany accounting
- Intercompany agreements
- Intercompany invoicing
- Intercompany netting
- Intercompany reconciliation
- Intercompany transactions
- Intercompany VAT
- Local file
- Low value-adding intra-group services
- Management fees and transfer pricing
- Master file
- Mutual agreement procedure
- Permanent establishment
- Pillar Two
- Service charge allocation
- Shared service centre pricing
- Transfer pricing in ERP systems
- Transfer pricing true-up
- VAT on management charges
- Year-end adjustment
Tools & technology
50 terms
- API Integration for Transfer Pricing
- Audit Trail for Transfer Pricing
- Benchmarking Database
- Cash Pool Interest Allocation Tool
- Cloud vs On-Premise Transfer Pricing Software
- Cost Allocation Software
- Country-by-Country Reporting Software
- Credit Rating Tool for Transfer Pricing
- Data Validation for Transfer Pricing
- ERP Transfer Pricing Integration
- Excel-Based Transfer Pricing Model
- Hourly Rate Calculator
- Intercompany Accounting Software
- Intercompany Agreement Repository
- Intercompany Charge Calculator
- Intercompany Invoicing Automation
- Intercompany Netting Software
- Intercompany Reconciliation Tool
- Interest Rate Benchmarking Tool
- Loan Pricing Tool
- Local File Automation
- Management Fee Allocation Tool
- Margin Monitoring Tool
- Master File Software
- NetSuite Intercompany Automation
- Operational Transfer Pricing Software
- Oracle Intercompany Module
- Pillar Two Software
- Royalty Calculation Software
- SAP Transfer Pricing
- Scenario Modelling for Transfer Pricing
- Segmented P&L Reporting Tool
- Tax Data Warehouse
- Tax Technology
- TP Controversy Management Software
- Transfer Pricing Analytics
- Transfer Pricing Automation Software
- Transfer Pricing Calculation Engine
- Transfer Pricing Dashboard
- Transfer Pricing Data Model
- Transfer Pricing Documentation Software
- Transfer Pricing Implementation Software
- Transfer Pricing Reporting Automation
- Transfer Pricing Risk Dashboard
- Transfer Pricing Workflow Management
- Treasury Management System
- True-Up Calculation Tool
- VAT Determination Engine
- Version Control for Transfer Pricing Models
- Year-End Adjustment Automation
Turn the theory into calculated, reviewable intercompany charges
Definitions are the easy part; producing defensible numbers every close is the work. Our tools calculate intercompany charges, benchmark financing rates and reconcile balances from your own data, so each figure you file can be traced straight back to the policy and the source ledger behind it.