-- The conditions that drove PE returns through the last cycle are less reliable today. Generating consistent returns requires deeper operational engagement inside portfolio companies — better processes, better data, and decisions made with better information.
Transfer pricing execution belongs on that list. For any portfolio company with cross-border operations, intercompany pricing determines how profit is allocated across entities within an arm's length framework — and therefore what the group's effective tax rate is. Execute it well and the ETR reflects the intended structure. Leave it unmanaged and value leaks through the hold period without visibility into how much or where.
Most treat it as a compliance exercise. It is not.
Where returns erode
Every PE-backed multinational has a transfer pricing policy. Very few have the operational infrastructure to execute it consistently.
The gap between policy and practice is where value disappears.
Manual OTP processes cannot guarantee that intercompany charges are calculated on the correct basis. Errors in data inputs or methodology go undetected, profit allocates to the wrong entity, and the ETR deteriorates without visibility.
Prices that were correctly set become stale as business conditions evolve. When corrections are made too infrequently — as they typically are in a manual process — a portion of the ETR impact becomes permanent and unrecoverable.
Every acquisition, carve-out, or restructuring requires a policy update. Manual processes take months to operationalise that change — during which intercompany transactions run on an outdated basis that may no longer reflect arm's length conditions.
The charges appear in the accounts. Whether they are correct relative to arm's length policy does not.
Why the urgency is real
The compliance burden on intercompany pricing has increased materially. Tax authorities are scrutinising transfer pricing positions more closely, documentation requirements have tightened, and Pillar Two has introduced a continuous reporting obligation that draws directly on intercompany transaction data. For portfolio companies operating across multiple jurisdictions, the bar is higher and the cost of getting it wrong is greater.
The commercial case is equally direct. Most PE portfolios have exhausted the easy operational levers. Transfer pricing execution remains one of the few that is both material in ETR impact — through correct arm's length compliance — and systematically unmanaged. Not because firms lack the intent, but because the infrastructure to manage it has not existed until now.
What stood in the way
For many companies, OTP falls between two functions. The external adviser designs the policy; finance owns the systems and the data. Neither controls the execution layer that sits between them. The result is a gap with no clear owner and no visibility into whether what is being executed matches what the policy requires.
For others, the effort has not justified the investment. Structuring intercompany data across multiple ERPs in a TP-specific framework has historically required specialist resource, custom configuration, and implementation budgets that most mid-market companies cannot justify — particularly when the leakage itself is not visible. Generic ERP modules and FP&A tools were not built for TP logic. What existed was expensive to build and fragile to maintain.
SyncDay was built to remove both barriers. Built specifically for transfer pricing — not adapted from a generic tool — it creates a TP model that is maintainable and scales as the business grows. Deployment is turnkey, IT lift is low, and it is designed to be used by finance teams without TP technology expertise.
What controlled execution delivers
A portfolio company with structured OTP infrastructure operates differently at every stage of the hold period.
In-year, intercompany charges are executed on the correct basis and monitored against arm's length policy at the right frequency for each transaction type. The CFO has a live view of the ETR position by entity and jurisdiction — not an annual surprise from the tax provision. When the group evaluates a restructuring or acquisition, the arm's length pricing and tax charge implications of each option are modelled before commitments are made. Decisions remain commercially driven; the ETR consequences are visible inputs, not post-closing discoveries.
At exit, there is nothing to reconstruct. A consistent record of arm's length execution and contemporaneous documentation means buyers find a clean position. The TP risk discount that transfer pricing exposure typically commands in due diligence does not apply.
Two models, one platform
How portfolio companies operationalise OTP varies, and rightly so. Some build internal capability — a tax or finance team that owns execution directly. Others externalise to specialist TP advisers, with the CFO retaining full visibility and control over what is being executed on their behalf. SyncDay supports both models. The choice belongs to the CFO and the operating partner.
Where externalisation makes sense, SyncDay gives the TP adviser a scalable delivery platform and the CFO a transparent audit trail. TP consulting firms have long seen the opportunity in managed OTP delivery. The constraint has been technology — no platform existed that made it scalable and controlled. SyncDay is partnering with leading TP firms to become that execution layer, enabling them to deliver OTP as a service without the manual overhead that has made it impractical at scale.
Built by people who lived this problem
SyncDay was founded by Adrien Piron, a former EY Director who spent a decade leading ERP and finance transformation initiatives for multinationals — with firsthand knowledge of where these systems fall short for operationalising TP, and Nadia Boughaba, a former McKinsey consultant who worked with multinationals on growth strategy and M&A, where modelling the full financial and tax implications of a decision before committing to it is the difference between good and poor strategic outcomes. Neither had seen a platform that covered the full TP lifecycle.
SyncDay was built because the infrastructure did not exist. It does now.
The window to act
Compliance requirements are tightening. PE returns depend increasingly on operational execution. For the first time, the technology exists to operationalise transfer pricing without the cost and complexity that made it impractical.
Companies that get OTP right protect returns, make better decisions, and face regulators from a position of strength — at a fraction of the cost of defending a position that was never properly controlled.
SyncDay is a cloud-native operational transfer pricing platform serving mid-market multinational enterprises and their advisers. syncday.com
Adrien Piron, Co-founder · [email protected] · linkedin.com/in/adrienpiron
Contact Info:
Name: Gianmarco
Email: Send Email
Organization: Xraised
Website: http://www.xraised.com
Release ID: 89188829
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