For a number of Greek headquartered firms, transfer pricing has traditionally been viewed as an annual compliance exercise —a technical report done for the tax authorities and then filed away. However, nowadays, domestic and foreign tax authorities expect more, not simply documents, everything that is stamped “Complied” needs to be monitored in real-time.

Operational Transfer Pricing (OTP) fills this gap. It is a practical method that enables businesses to manage their transfer pricing in such a way that entails more than just compliance on paper—for a given month, for every entity, and for every level of the organization.

At PwC Greece, we assist companies in migrating from passive transfer pricing policy frameworks to dynamic, integrated policy operating systems that enhance, rather provide for, tax compliance and internal controls. With OTP, companies are able to:

  • Monitor intercompany profit levels throughout the year, not just at the year end.

  • Evaluate what the actual role and contribution of each group entity is within the structure and identify its risk profile.

  • Minimize manual actions to achieve uniformity across countries and divisions;

  • Improve the ability to defend their position during audit or negotiations with tax authorities or during APAs.

In addition, OTP supports a more strategic view of the group’s tax position. By aligning transfer pricing outcomes with financial data in real time, companies can analyze how profits — and therefore taxes — are distributed across jurisdictions. This enables better management of the effective tax rate (ETR), early detection of potential issues, and more informed decision-making for future planning.

OTP is especially valuable for companies with centralized structures, cross-border sales, or they want to establish shared service models. It helps finance and tax teams translate high-level policy into daily business operations, ensuring the right margins are realized by the right entities.

More broadly, it gives leadership teams the clarity they need to understand where value is created, how it’s priced, and whether the current model is working as intended.

“For Greek businesses growing internationally, transfer pricing needs to move from the back office to the boardroom. Operational TP helps ensure compliance while improving control and decision-making.”

— Dimitris Arampatzs, Transfer Pricing Director, PwC Greece

Call to Action:

If your business is rethinking how it manages transfer pricing in practice — or facing new expectations from tax authorities — contact PwC Greece’s dedicated transfer pricing team to explore how an OTP approach can work for you.