For finance and legal teams
Your entities, agreements, benchmarks, and local files live in one record, from the first form to the signed version.
Transfer Pricing Handled for Every Entity
Documentation and benchmarking for your whole group, plus monitoring that pulls intercompany transactions from your accounting system and flags any that drift from policy.
Commenda's operational transfer pricing overview: five intercompany pairs with their arm's length ranges. Asked which pairs are outside policy this quarter, Commenda AI answers that Commenda Holdings Inc. to Commenda Asia Pte. Ltd. is below range at 3.20% against 4.0 to 9.0%, with an adjustment of $38,200.00 needed, and that Commenda UK Ltd to Commenda Technologies Inc. is near the edge at 5.80%.
TRUSTED BY
Over 1,000 customers. 80+ countries supported.
WHO IT'S FOR
One platform for transfer pricing
We do it end to end for finance and legal teams. Firms with their own transfer pricing practice run their clients' work on Commenda.
For firms
Run every client's transfer pricing from one workspace. Set up your team and workflows once, and each client's work follows them.
WHY COMMENDA
Why finance teams hand us their transfer pricing
Keep all documents in one place
Agreements, benchmarks, local files, master files, and CbCR for every entity in your group, with each signed version kept.
Hand the review to an expert
Our software prepares each document from your entity data, and our transfer pricing expert reviews and signs it off.
Get agreements within 10 days
Benchmarks in 10 to 14 days and local files in 15 to 20 once both exist, counted from payment and your completed form.
Pay a fraction of Big Four fees
The same documents at a fraction of what traditional firms and the Big Four charge.
POLICY AGREEMENTS
Draft a policy agreement for each type of deal
- Counted by type of dealServices and a loan between the same two companies are two agreements.
- Built on how your companies workEach company's functions, assets, and risks, with the method, markup, and payment terms.
- Linked to its benchmarkThe markup sits next to the range that supports it.
BENCHMARKING
Benchmark against independent companies
- Your arm's-length rangeUsually the interquartile range. India uses the 35th to 65th percentile when there are 6 or more comparables.
- The full search on fileEach study keeps its search specification and rejection matrix, from the commercial databases relevant to your geography.
- Reviewed by youYou give us the business information, we run the study, and you check it before it's final.
DOCUMENTATION
Prepare local files, master files, and CbCR
- A local file for each countryWith the functional and economic analysis, in that country's format, once its benchmark and agreement exist.
- A master file for the groupYour structure, business, intangibles, financing, and financial and tax positions.
- CbCR where you need oneFor groups with €750m or more in prior-year revenue.
OPERATIONAL TRANSFER PRICING
Check each margin before year end
- Actuals against your targetTransactions come from your accounting system and are tested against the markup and range in each pair's policy agreement.
- The adjustment, before year endYou see it during the year, while there is still time to book it.
- Set up around your systemsSold separately and priced after we review your setup. If we don't connect to your accounting system yet, we build the integration.
AND MORE
Everything else your transfer pricing needs
Your records, the alerts we turn on when you need them, and the services you can add.
Your entities in one place
Your group structure, each entity's business details and IDs, and its formation documents, in one record.
Version history and redlines
Every version is kept with its redlines and owners, so your documents are audit-ready. We turn it on for your account when you need it.
Deadline and renewal alerts
Email alerts for transfer pricing deadlines and renewals, which we turn on for your account when you need them.
Advisory calls
Add-onA call with our transfer pricing expert to answer questions about your own group or plan a new setup.
India Form 3CEB and Form 48
India planIndia's yearly accountant's report on cross-border deals with related companies, inside our India managed-entity plan.
Same-country related parties
Add-onTransfer pricing for deals between related companies in the same country, where the rules apply.
HOW IT WORKS
How we run your transfer pricing
Onboard once. Your entity details carry into every document, so we don't keep asking.
COMMENDA AI
Ask Commenda AI about your transfer pricing
Ask about your entities, policies, and benchmarks. The answers come from your own records, and the same question gets the same answer.
CUSTOMERS
What teams say about working with us
Controllers, counsel, and operations leads on how the work gets done.
“The platform works exactly the way I need it to. As long as the Commenda team is actively logged in, filing, and providing us with a summary report, I consider that my measure of compliance.”
Matt PrestonFinancial Controller, TRX
“The Commenda team is delivering ahead of schedule and with quality.”
Luis Cerqueira da SilvaEntity Governance Manager, Remote
“Everyone has been a pleasure to work with, demonstrating a high level of expertise and knowledge.”
Olya MassalitinaDirector of Finance, Loulou Lollipop
“Eventually we even decided we want to migrate accounting and tax-related services to Commenda and consolidate it in one place.”
Stacey TaraHead of Global People Operations, Exa
“It’s so fast. It’s impressively fast. It is faster to ask Commenda AI what is going on than for me to go do it.”
Rich FrazierGeneral Counsel, Wetstone
“Commenda is a great tool for entrepreneurs like myself primarily because of its simplicity.”
Cameron RoweFounder, HoverQUESTIONS
FAQs
What finance teams ask before they move their transfer pricing over. If yours isn’t here, ask an expert directly.
Yes. Almost everywhere, deals between related companies must be priced as if the companies were unrelated, from the first transaction. Each country's own tax law sets and enforces the rules, and most base them on the OECD Transfer Pricing Guidelines. In the US, documentation only protects you from penalties if it exists when the return is filed, and you have 30 days to hand it over if the IRS asks.
OECD BEPS Action 13 set three: a master file for the group, a local file for each entity, and a country-by-country report. CbCR applies to groups with €750m or more in prior-year revenue ($850m in the US). Master and local file thresholds vary: Ireland asks for a local file from €50m of group revenue, the Netherlands for both from €50m, and France from €150m of turnover or gross assets. The US asks for neither; its own documentation protects against penalties.
No. Each item stands on its own: a policy agreement, a benchmark study, a local file, a master file, or a country-by-country report. Buy one, or several together.
Yes. Upload them to Commenda, and our transfer pricing expert tells you whether any of them need refreshing.
OECD guidance allows a full new search every 3 years, with the comparables' financials updated each year, if your business hasn't changed. India requires current-year data, so in practice a new benchmark every year. If what your companies do changes, the study should be redone straight away.
Authorities usually adjust to the median. The fix is a true-up booked before year-end close; in the US it must be on a timely filed original return. With operational transfer pricing, you see the adjustment needed during the year, before the books close.
No. Every Indian entity with any cross-border related-party transaction needs a CA-signed accountant's report each year: Form 3CEB up to FY 2025-26 (due 31 Oct 2026), then Form 48 from tax year 2026-27. ₹1 crore only decides whether the full transfer pricing study is mandatory. The report is part of our India managed-entity plan. If we don't manage your Indian entity, your own CA files it.
Policy agreements take 7 to 10 days and benchmarks 10 to 14 days. A local file takes 15 to 20 days once its benchmark and agreement exist, and a master file or CbCR takes 1 to 2 months. Each clock starts when you've paid and sent the completed form. Operational transfer pricing is a custom setup, so its timeline depends on your systems.
We prepare and keep the documentation a tax authority asks for. Your local accountant or tax counsel represents you.
Yes. Commenda is SOC 2 Type II compliant.
GET STARTED
Start with your first policy agreement
Book a demo to see how we run your policy agreements, benchmarks, and local files.
