Operational Transfer Pricing (OTP)

With global tax reforms reshaping regulatory expectations, intercompany transactions are under unprecedented scrutiny making the structuring and execution of transfer pricing policies have never been more consequential. A robust operational transfer pricing strategy bridges the divide between policy and practice—aligning tax, controllership, treasury, and shared services to ensure cohesive execution.

PwC's Operational Transfer Pricing (OTP) is uniquely positioned to help clients capitalise on these opportunities, offering end-to-end support from data extraction and transformation, to the design of segmentation, allocation, and calculation frameworks, through to outcome modelling and output generation.

Our approach is technology-agnostic and tailored to each organisation's strategic objectives. We collaborate with clients to enhance data integrity, leverage existing technology investments, and establish scalable governance models. Solutions may be embedded within broader ERP migrations or finance transformation programmes, or delivered as standalone transfer pricing initiatives—whether through short sprints or multi-year integrations.

By leveraging OTP, we provide actionable insights for audit defence, support transfer pricing planning from execution to documentation, and facilitate continuous improvement through IT system upgrades.

How we have helped?

  • Provided numerous MNCs with various TP technology solutions that enable automatic financial segmentation, compliance report preparation, TP modeling and data analytics.

Contact us

Jeff Yuan

Jeff Yuan

Head of Tax, PwC China

Tel: +[86] (21) 2323 3495

Paul Tang

Paul Tang

Transfer Pricing Services Leader, PwC China

Tel: +[86] (21) 2323 3756

Kevin Tsoi

Kevin Tsoi

Partner, PwC China

Tel: +[86] (20) 3819 2380

Cecilia Lee

Cecilia Lee

Partner, PwC Hong Kong

Tel: +[852] 2289 5690

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