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Solution · Finance & accountingThe factual half of every local file written from the ledger, ready for your adviser
Transfer pricing files assembled from the ledger
Robots extract intercompany turnover per entity and category, reconcile it to the statutory accounts, pull the governing agreements and generate the local-file sections from approved Word templates.
Executive summary
Every filing season your team rebuilds the same tables, from the same ledgers, in Word, from scratch.
The engine Mientha builds starts at the ledger, not the document.
The factual part of every local file exists within days of the ledger being final.
the SharePoint documentation library and its retention; the Word sections and their PDF renditions; the reconciled workbook for the adviser and the TPR
Business problem
Tax documentation
Transfer pricing documentation shows a tax authority that transactions inside a group are priced the way they would be between unrelated companies. It has two halves. One is judgement: the functional analysis and the comparability study that make the price defensible, and that half belongs with a tax adviser. The other is fact: what each entity bought from and sold to related parties last year, by counterparty and category, tied to the audited accounts, with the governing agreement named.
The factual half is where the season goes. Intercompany turnover lives in the ledger but not in the shape the file needs: postings carry a trading partner, a document type and a GL account, and turning eleven entities' postings into six documented categories is a mapping somebody reconstructs from memory every year. Totals must then agree with the statutory accounts, because a figure a reviewer cannot find in the financial statements is the first one questioned. The agreements are somewhere: a register, a drive, a mailbox.
Three roles carry this and none owns it. The group tax manager assembles and formats, entity controllers export on top of a close they have just finished, and the adviser waits for the facts. Every entity entering the obligation adds six more sections and every acquisition an unmapped chart of accounts, while the deadline holds because a statute sets it. What gets compressed is never the formatting. It is the reading.
How it works today
This is the shape of a filing season in most groups documenting more than a handful of entities.
- PersonThe group tax manager asks each entity controller for intercompany turnover by counterparty and category, with last year's template attached
- WaitingReplies come back over three to five weeks in whatever the local system exports, and two entities need reminding
- PersonFigures are pasted into a consolidation workbook and reconciled by hand to the statutory accounts, which rarely agree with the ledger cut
- PersonSomeone hunts the register, the shared drive and the entity's folders for the agreement behind each category, then reads it for price basis and term
- SystemLast year's Word file is copied, the tables overwritten, the text edited wherever somebody noticed the business had changed
- Risk of errorA category that crossed a documentation threshold is spotted late, and the TPR figures are keyed from a different export
Why the current process costs more than it appears
Nobody planned this work; it accumulated.
- Assembly crowds out analysis. The weeks that go into extracting and formatting are the weeks somebody should spend asking whether the pricing still matches what the entities do.
- Each reply arrives in its own shape, so the mapping is rebuilt by hand every year. Ask in March which accounts fed the royalty section and the answer is a workbook nobody kept.
- Reconciliation differences are settled quietly. A total that does not tie to the statutory accounts is explained in a sentence rather than traced, and the sentence is filed nowhere.
- Threshold testing happens during drafting, the worst moment for it. By the time anyone notices a recharge grew past the documentation limit, there is no time to do more than describe it.
- Nothing here survives a departure. The mapping, the reconciliation logic and the knowledge of which agreement covers which flow sit with two people who have to be there in September.
Cost of inaction
The file is always delivered. That is precisely why this never reaches a management agenda: the tenth month closes with a signed local file, the eleventh with the TPR figures, and the cost sits in a season rather than a budget line. What the arithmetic misses is the shape of the year, in which the same autumn weeks go into tables and the reading that defends the group's position is done last and quickly.
Exposure accumulates on the other side of the file. A total nobody can trace to the statutory accounts, or a recharge that quietly passed a threshold, is rarely found by the group; it is found by someone comparing the reported figures with the accounts, by which time the year is closed and whoever built the mapping has moved on.
A plausible organisation with realistic proportions. The figures are there to be recalculated on your data; they are not a client result.
A Central European manufacturing and distribution group, 11 documented entities in 8 countries, about 1,800 employees; seven on SAP S/4HANA company codes, four on systems inherited with acquisitions; Microsoft 365 E3; group tax is one manager and an analyst, with an external adviser for comparability studies.
6 documented categories per entity, being goods, management services, IT recharges, royalties, intercompany loans and guarantees; 66 local-file sections a year, plus a master file and the figures reported on the TPR form.
Requests go to eleven controllers, exports return in nine layouts, the mapping is rebuilt in Excel, agreements are hunted individually, and last year's Word file is copied and overwritten.
About three and a half hours per section from first request to signed draft, concentrated into the weeks before the statutory date.
Robots extract intercompany turnover per entity, counterparty and category, reconcile it to the statutory accounts, read the governing agreement and its terms from the contract register on SharePoint, and generate each section from an approved Word template; tax signs off in Microsoft Teams and the pack is archived with a retention label.
In the modelled case the first complete factual draft exists within days of the ledger being final rather than in the tenth month, and the adviser receives the facts early enough to price the analysis. The figures are a model, not a measurement.
Proposed solution
The engine Mientha builds starts at the ledger, not the document. On the filing calendar, robots extract the year's intercompany postings from every entity: the SAP company codes through BAPI and OData, reading trading partner, document type and account range; the local systems through their own API or a scheduled export. One versioned mapping table, owned by group tax, turns postings into documented categories, each total reconciled to the entity's statutory accounts with any residual named.
Agreements come from where they already are. The contract register on SharePoint holds them with metadata: parties, transaction type, price basis, effective date, term. Robots write the reference and terms into the section, and a category above threshold with no current agreement goes to tax before drafting.
Generation is deterministic. Each category has an approved Word template whose content controls mark the only fields the flow may write; robots fill the tables, save a PDF rendition and attach a summary of what differs from last year. The draft reaches the entity controller and the group tax manager as an approval in Microsoft Teams, and the signed pack is filed on SharePoint under a Microsoft Purview retention label. Comparability studies stay with your adviser; we remove the wait for the facts they analyse.
UiPath Orchestrator time triggers, queues, credential store and audit; SAP BAPI and SAP OData connectors, with SAP WinGUI activities where no interface exists; UiPath Integration Service connectors for Microsoft OneDrive & SharePoint and Microsoft Teams, plus Connector Builder; UiPath Word activities; Word content controls; SharePoint libraries; Microsoft Teams Approvals app; Microsoft Purview retention labels
The mapping from GL account, trading partner and document type to your documented categories; extraction per ledger on the filing calendar; the reconciliation and its difference rules; the threshold test; the template set; the change summary; review, filing, exceptions and the status board
SAP S/4HANA extraction through BAPI and OData; the local ledgers through their own interface or a scheduled export; the transaction workbook in the format your adviser and the TPR form need
How the automated process works
- AutomationOn the filing calendar Orchestrator starts one job per entity; robots extract the year's intercompany postings by counterparty, account and document type
- AutomationThe mapping table turns postings into documented categories, and every total is reconciled to the statutory accounts with any residual named
- AutomationEach category is tested against the documentation thresholds and written to the entity's scope list, so one crossing a limit is visible before anyone drafts
- AutomationThe contract register is queried for the agreement behind each category and its price basis, effective date and term; a category with no current agreement becomes an exception
- AutomationEach section is generated from the approved Word template for its category, tables filled and wording untouched, with a PDF rendition and a change summary
- PersonThe entity controller and the group tax manager review and sign off in Microsoft Teams, with the reconciliation and the exceptions attached
- AutomationSigned sections are filed on SharePoint under a Purview retention label, the reconciled workbook goes to the adviser and the TPR preparer, and a status board in the tax channel shows progress against the statutory dates
Human-in-the-loop model
Automation handles
- Extraction of intercompany turnover from every ledger and its mapping to documented categories
- Reconciliation to the statutory accounts, the naming of any residual, threshold testing and the scope list
- Retrieval of agreements and their terms, section generation from approved templates, filing with retention and the status board
People decide
- Whether a category total and its reconciliation are correct, per entity, in Teams
- The functional text, and what happens when a documented category has no current agreement, which is a legal question rather than a drafting one
- The mapping table, the thresholds and the template wording, owned by group tax and versioned
Before and after
Systems and integrations
Everything below runs on licences and systems you already hold, or would need anyway.
Inputs
- SAP S/4HANA intercompany postings and trading-partner data
- extracts from the local ledgers
- the contract register on SharePoint
- the statutory accounts per entity
- the mapping and threshold tables
Automation layer
- UiPath Orchestrator
- UiPath Robots
- UiPath Integration Service
- UiPath Word activities
Target systems
- the SharePoint documentation library and its retention
- the Word sections and their PDF renditions
- the reconciled workbook for the adviser and the TPR
Human touchpoints: review and sign-off in the Microsoft Teams Approvals app; the status board in the tax channel; the exception list for missing agreements
Technologies used
one job per entity on the filing calendar, queues, retries, credentials, audit
Aintercompany postings, trading-partner data and balances from the SAP company codes
Areads the register, files the pack, raises the review, reaches the local ledgers
Aapproved templates whose content controls are the only fields robots fill; tables inserted, PDF saved
Aentity review and group tax sign-off, with draft and reconciliation attached
Athe reconciliation and transaction workbooks, the documentation library and its metadata
Aretention labels on the filed documentation and the audit of who approved what
AIllustrative economic model
A model, not a promise.
The whole model is sixty-six sections a year, spread unevenly across a filing calendar; the calculator reads them as five and a half a month so the arithmetic matches the rest of this library. Three and a half hours per section covers chasing an export, mapping it to a category, reconciling to the statutory accounts, retrieving the agreement, filling the template and one round of review. The comparability study is not in that figure and never becomes ours. €45 an hour is a fully loaded group tax cost in Central Europe.
Run the numbers on your data
An illustrative estimate from your own inputs. It models released capacity; it is not a promise of savings.
Business benefits
- The factual part of every local file exists within days of the ledger being final, so drafting starts early rather than in the month before the deadline
- Tax spends the season on the text that needs judgement rather than on rebuilding turnover tables
- Every documented figure ties to the statutory accounts by rule, and a residual carries a name and an owner
- Categories crossing a documentation threshold surface at extraction, not when somebody is already writing about them
- The adviser receives a reconciled pack at a predictable moment, and a new entity costs a mapping entry and a template rather than six more sections
The management view
- Filing status stops being a meeting question: sections extracted, drafted, reviewed and signed are visible per entity against the statutory date
- The mapping from ledger to documented category becomes a versioned artefact the group owns, not knowledge held by whoever did it last
- Documentation risk becomes measurable, because categories above threshold without an agreement and reconciliations with an open residual are both counted, and the obligation scales with the group rather than with the tax team
Board-level KPIs
Security and governance
Trust in automation is built on the audit trail, not on a promise.
- Each ledger is read by a robot account with display rights on the intercompany accounts and nothing more; the automation never posts, and every read is logged
- Eleven sets of ledger credentials are drawn at runtime from the credential store your tenant already uses, Orchestrator's own or Azure Key Vault, and each retrieval leaves a record
- Your Microsoft 365 tenant stores the documentation, exports, drafts and approvals; the platform assembling them runs in UiPath Automation Cloud, EU region
- No section is filed on one person's word: the entity controller and group tax both act in Teams, Purview holds the audit of who approved what, and the mapping table, thresholds and template wording are versioned under the group tax manager's approval
Why now
The calendar belongs to the legislator. In Poland the local file is due by the end of the tenth month after the tax year, the TPR information by the end of the eleventh and the master file by the end of the twelfth
Assembly absorbs the modelled €866 a month of group tax capacity, in exactly the weeks when the functional text should be getting attention
Nothing here needs a model to read anything: postings come out of SAP through standard BAPI and OData interfaces, agreements and their terms already sit as metadata in a register, and a Word template with content controls is filled the same way every year
Relevant executive roles
The group's tax position rests on figures reproducible from the ledger on demand, and the season stops consuming the reporting team's autumn
The factual pack arrives complete and reconciled, so the season goes on analysis instead of chasing eleven exports
One mapping from ledger to documented category in every entity, with the reconciliation made explicit instead of assumed
Common questions and objections
They prepare the part that needs their judgement, and they should keep it. What they cannot do cheaply is extract your ledgers, map postings to categories and reconcile to the statutory accounts, so they wait for you and bill for the wait. This shortens it.
The template holds the structure and the approved wording, not the facts. Amounts, counterparties, agreements and terms come from the ledger and the register each year, and the change summary shows what moved. A genuinely new arrangement needs a new section and a decision from tax.
From the ledgers, through interfaces rather than screens wherever they exist: BAPI and OData for the SAP company codes, the local system's API where it has one, a scheduled export where it does not. The mapping is built once with your tax team and versioned.
When this is not the right solution
- Groups documenting two or three entities with a couple of categories each, where a disciplined workbook costs less than an automation
- Ledgers with no usable trading partner or intercompany account structure, so nothing identifies a related-party posting; an ERP problem to fix first
- Groups renegotiating intercompany arrangements constantly with no contract register behind them, where the missing register is the real problem
A question for the next management meeting
By what date after the ledger closes could this group produce a complete, reconciled transfer pricing file, and what stands between that date and the one we actually work to?
Implementation approach
The first week looks the same at every client: we look at the data.
We deliver
- One completed filing year taken apart with you: the real categories, the volumes, the export each ledger produces and where the reconciliation broke
- The mapping from GL account, trading partner and document type to your categories, readable by an adviser and an auditor alike
- Extraction per entity across the SAP company codes and the local systems, on your filing calendar
- The reconciliation to the statutory accounts, its difference rules and the threshold test
- The template set, generation with PDF renditions and change summaries, review in Teams, filing with retention, then rollout entity by entity
We need from you
- Last year's local files and the exports behind them, for two entities of different sizes
- A process owner in group tax, plus whoever approves the mapping and the template wording
- Technical accounts with display rights on the intercompany accounts, and access to the register
- Your adviser's view on the format of the pack they want
Stages
Discovery
One completed filing year: categories, volumes, ledgers, reconciliation breaks, where agreements live
Design
Mapping table, difference rules, thresholds, template set, review and filing model
Build
Extraction per ledger, mapping and reconciliation, generation from templates, review in Teams
Validation
Regeneration of a completed year, compared line by line with what was filed
Go-live
A first live season on part of the group under supervision, then the rest
Departmental. Effort follows the number of source systems and the state of the ledger rather than the number of entities: one chart of accounts with a reliable trading-partner field is a short project, five systems and free-text references are not.
Last year's local file is still the fastest way to write this year's.
Send us one entity's local file from the last filing year with the exports behind its tables. We come back with the share a rule could have produced and the figures that would not have reconciled.
Rebuild one local file from the ledgerThe neighbouring process usually has the same problem
Your entities disagree about what they owe each other, and the consolidation waits for an email.
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View solutionIndustries we deliver this in most oftenManufacturing & industryRetail & e‑commerceServices & ITShared services