Reconcile intercompany agreements with the transfer pricing policy
For: Group tax manager or group controller preparing transfer pricing documentation
The pain today
Markups, payment terms and service scopes are set in the transfer pricing policy, restated in intercompany agreements and changed in addenda. For many entity pairs they no longer agree, and a tax authority finds it first.
The ask
“I attached our transfer pricing policy, the intercompany service and loan agreements and their addenda. For each pair of group companies, tell me the markup or interest rate, payment terms and services covered, with the source, and show where an agreement disagrees with the policy or with its own addendum.”
Plain words, as you would say it to a colleague. Edit it to fit your case before you send it.
What you attach or connect
- Transfer pricing policy
- Intercompany service, licence and loan agreements
- Addenda and renewal letters
- List of entity pairs and transaction types
The unit of work
One worker task per one entity pair's agreements.
Why a swarm fits
Each entity pair is answered from its own agreements plus one policy section. Pairs are independent, the questions are identical, and the value lies in the disagreements between documents.
Not for
A group with a few entities and one template agreement: reading them directly is quicker than setting up a run.
The decision tree
6 typed decisions, each with an action for every answer
At fixed moments in a run, the engine puts one narrow question to a decision model. The decision model never writes text: it answers yes or no with a probability, picks from listed options, or gives a score, about a small slice of the material. The engine then does exactly what this tree says, which is what makes the run auditable. The thresholds are the template's design values, not measured results.
Planner, while planning
Scope checkYes or no, with a probability
Before work starts on a unit
Is this document an agreement or addendum between the two named group companies, rather than a policy extract or an invoice?
Sees only: The title, parties and signature block
Why: Keeps each entity pair's file to the documents that set its terms.
- Yes: 0.60 or higherthenAccept
- Unsure: 0.30 up to 0.60thenAccept
- No: below 0.30thenSkip this unit
Before workers, before a task runs
Small worker or strong modelYes or no, with a probability
Before a task runs
Does this entity pair have a single agreement with no addenda, renewal letters or overlapping service scopes?
Sees only: The pair's document list with dates
Why: Pairs with layered addenda go to a stronger reader.
- Yes: 0.60 or higherthenAccept
- Unsure: 0.40 up to 0.60thenEscalate to a strong model
- No: below 0.40thenEscalate to a strong model
After workers, the judge checks
Evidence checkYes or no, with a probability
After a worker answers
Does the quoted clause state the markup or interest rate for this transaction type between these two companies, with an effective date?
Sees only: The extracted rate, the quoted clause and the document date
Why: A rate lifted from the wrong service schedule misstates the whole pair.
- Yes: 0.85 or higherthenAccept
- Unsure: 0.50 up to 0.85thenEscalate to a strong model
- No: below 0.50thenReject and retry
Evidence checkYes or no, with a probability
After a worker answers
Was the agreement still in force for the period under review, by its term clause or a renewal letter on file?
Sees only: The term clause, any renewal letter and the review period
Why: Expired agreements still relied on are a finding of their own.
- Yes: 0.85 or higherthenAccept
- Unsure: 0.50 up to 0.85thenMark unresolved
- No: below 0.50thenMark unresolved
Reconciler, while merging
Conflict checkA choice among options
While reconciling
How does the agreement's rate or payment term compare with the policy position for this transaction type?
Sees only: The extracted term and the policy passage for the transaction type
Why: The value of the run is the list of disagreements, kept open.
- Same as policythenAccept
- Differs from policythenMark unresolved
- Agreement and its addendum differthenMark unresolved
- Policy is silent on this typethenAsk a person
Accountable person, before anything is settled
Person decidesYes or no, with a probability
Before anything is reported as settled
Would settling this item mean amending an agreement or the policy, or defending a deviation to a tax authority?
Sees only: The deviation with both sources
Why: The group tax manager decides which position is correct.
Accountable: The group tax manager decides which position is correct and whether agreements or the policy must be amended.
- Yes: 0.40 or higherthenAsk a person
- Unsure: 0.15 up to 0.40thenAsk a person
- No: below 0.15thenAccept
The fleet: who does what
Model tiers by role, not brands: you choose the models. Strong reasoning models plan and reconcile, small fast models do the wide work, and the judge is a decision model from a different family, so it does not share the workers' blind spots.
Planner
A strong reasoning model extracts the policy position per transaction type and sets the questions for each entity pair.
Decisions here:1. Scope check
Workers
Small fast workers from an open-weight family extract terms for one entity pair with quotes, dates and signatories.
Designed for 4 to 120 agents, one worker task per one entity pair's agreements. Each worker receives only its own unit.
Decisions here:2. Small worker or strong model
Judge, from a different model family
A decision model from a different family checks that each quoted clause supports the extracted rate, term or scope.
Decisions here:3. Evidence check4. Evidence check
Reconciler
A strong reasoning model compares each pair with the policy and keeps agreement-versus-addendum conflicts open.
Decisions here:5. Conflict check
Accountable person
The group tax manager decides which position is correct and whether agreements or the policy must be amended.
Decisions here:6. Person decides
Checked before anything is accepted
- Every rate, term and scope carries a quote, document name and effective date
- Addenda are applied in date order and unsigned versions are marked
- Expired agreements still relied on are reported separately
- Claims without a supporting passage are retried, then refused
What comes back
- Terms per entity pair and transaction type, with sources
- Deviations from the transfer pricing policy
- Conflicts between agreements and their addenda
- Entity pairs with transactions but no valid agreement
What to measure
- Deviations a tax manager confirms
- Terms found wrong in a hand-checked sample
- Hours to prepare the agreement section of the documentation
Names of measures only. No result is claimed for this template.
Templates open in the workspace chat with the ask filled in. Nothing runs until you send it.
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