Maps. Benchmarks. Documents. Reports
Maps every intercompany transaction across the group. Benchmarks against external comparables. Drafts OECD BEPS Action 13 documentation — Master File, Local File, country-by-country report. Group tax shifts from 3-month annual scramble to continuous compliance, refreshed quarterly.
By the numbers
The use case
Group tax responsible for OECD BEPS Action 13 compliance across 15 jurisdictions. TP documentation is 8 weeks of audit-firm work every year, billed at €400K. The IC transaction list never agrees across subsidiaries — sub-A invoices €2M of services to sub-B, sub-B books €1.7M, finance closes the difference as variance. TP audit risk is unknown — the Big-4 charges to estimate it. CbCR is two weeks of Excel followed by four weeks of consolidation.
Transfer Pricing Agent reads IC flows from Astral so the transaction list is one truth across the group, applies the comparables library to benchmark each category, drafts Master File and Local Files per jurisdiction per Action 13 format, generates CbCR ready for XML submission, and refreshes benchmarks annually. Group tax moves from annual scramble to continuous compliance — and the €400K consulting bill becomes a fraction of that for review only.
For who
Capabilities
Reads the entity graph and intercompany flows from Astral. Maps every IC transaction — goods, services, licenses, financing, cost-sharing — to its counterparty entity, its functional profile, and its TP policy.
Curated benchmark databases — license royalty rates, service-cost mark-ups, financing spreads. Refreshed annually with the latest publicly available data. Sets the arm's-length range per transaction category.
Drafts the group Master File per OECD Action 13 — organizational structure, business description, intangibles, intercompany financial activities, financial and tax positions. Ready for jurisdiction-specific submission.
Generates Local Files per jurisdiction with local-entity description, controlled transactions, functional analysis, comparables analysis, and financial information. Adapts to local Local-File format requirements.
Continue exploring
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