Industry & strategy
Operating models, industry value chains, business restructurings, and Pillar Two — where transfer pricing moves from compliance into how the business is built
Industry is where transfer pricing stops being generic. The same method applied to a medical device company and a software business produces answers that mean very different things, because value sits in different places — in regulatory approvals, in code, in customer relationships built by local marketing spend.
This cluster covers industry and strategy in working detail — how to design an operating model that matches the business, how value is created in life sciences, software, and consumer products, how to restructure without surprises, and what Pillar Two changes. Written for the tax leaders who shape the structure and the advisors who help them defend it.
How to design a transfer pricing operating model that matches the business.
Most transfer pricing models are designed once, around a structure chart, and then left alone while the business changes underneath them. This is a mistake. How to design an operating model where the pricing follows the people, the risks, and the value — and the six signs yours has drifted.
Read the full article →In this article
- The structure-chart problem
- Value creation: where is it actually happening?
- Entrepreneur, limited-risk, or routine: choosing the roles
- People functions: does the substance match the model?
- Business restructurings: changing the model safely
- Pillar Two: how a minimum tax changes the calculus
- Operational transfer pricing: making the model run
- Six signs your model no longer matches the business
Five pieces, each on one part of the work.
The pillar above is the comprehensive starting point. The articles below go deeper on individual elements — life sciences, software and SaaS, consumer products distribution, business restructurings, and Pillar Two.
Life sciences and medical devices: R&D, regulatory, and commercial value
Value in life sciences sits in development risk, regulatory approval, and market access, and those rarely live in the same entity. How to allocate returns across the chain, and the patterns tax authorities challenge most.
Software and SaaS: pricing intangibles that live in the cloud
Where code is written, hosted, and sold are often three different places. How to characterize development, platform, and distribution entities, and how subscription economics change the analysis.
Consumer products: marketing intangibles and the limited-risk distributor
When a local distributor spends heavily on advertising, the question is who owns the result. How the DEMPE framework applies to marketing spend, and when a routine return stops being enough.
Business restructurings: moving functions, risks, and profit without surprises
Converting a full-fledged distributor or centralizing IP raises the question of what was transferred and what compensation is due. How Chapter IX frames restructurings, and how to document one before it happens.
Pillar Two and transfer pricing: what changes under a global minimum tax
A 15% minimum tax changes the incentives behind low-tax structures, but not the arm’s length principle. Where transfer pricing and the GloBE rules interact, where they pull apart, and what in-scope groups should revisit.