One charge is two entries in two jurisdictions, so the agent drafts it, records the documentation that must exist before the return is filed, and holds both for the officer who signs.
A charge is raised, and under 6662(e)(3)(B)(i) its documentation exists before the return is filed.
02
The first GloBE return fell due 30 June 2026 and held, so the rule vintage rides each charge.
Reason
03
A method is settled under 1.482-1(c)(1), and the methods set aside are recorded beside it.
04
An examiner asks years later, and the file must be produced complete within thirty days.
05
A pool position persists year on year, and OECD Chapter X asks what it has turned into.
Decide
06
A loan sits unsettled, and the ASC 830 evidence is laid out for a person to classify.
07
A charge-out reaches the Country-by-Country Report, filed under 1.6038-4 with the return.
Out
08
Two ledgers agree and neither is defensible, and that is recorded as the finding.
09
Execute write actions only inside the approval boundaries fixed at implementation.
→Product statement
Drafting, documentation and the charge trail belong to the agent. The price belongs to a named officer, who signs under 26 U.S.C. 6062 and 6065 and owns it there.
Example workflow
One charge, both sides to signature
AgentHuman
1Documents receivedIntercompany agreements, cost pools, functional analyses, the master file and the local file
2Transaction characterised and versionedThe counterparties, the jurisdictions, the tested party and the tier it sits in under Action 13
3Both sides raised apartThe charge as raised, the charge as received, and the entry eliminating both under ASC 810
4Checks and controls appliedAgreement checks, document checks, elimination in full under IFRS 10 B86 and drafting confidence
No human action required
Stages 1 to 4 run unaided, and no price is fixed at any of them — the agent is assembling evidence, and the officer lane opens at the documentation gate.
5DecisionSplits at the documentation gate
File complete against the method
Goes to the named signing officer to approve.
Anything undocumented
Adds a transfer-pricing counsel read first.
Signing-officer review
The charge is held with its method file, its agreement and the ledger on each side of it.
Approve · Append document · Send for counsel review
Approved — by the named signing officer▼
6Ledger and consolidation records updatedOnly where write access and the group records policy allow it
7Charge evaluatedDocument completeness, method stability, officer corrections and what counsel review found
Corrections entered
Each correction the officer enters is weighed in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Setting the price on an intercompany charge.
Signing the return under penalties of perjury.
Deciding a balance is long-term investment.
Electing the side-by-side safe harbour.
Automation boundaryAgent acts unaided
✓Draft each intercompany charge against the agreement that governs it.
✓Record the method chosen and the ones set aside.
✓Show the counterparty ledger beside the one that raised the charge.
✓Hold the charge, its file and both ledgers as one.
No price is set except by a named officer, who signs under penalties of perjury.
Judging whether a service conferred a benefit.
Telling an examiner the method was reasonable.
Choosing the tested party and the comparables.
Changes to the charge, the ledger or the file.
Example output
One intercompany charge, annotated
This serves a group finance team whose charge-out is read from two sides and whose first Australian public report fell due on 30 June 2026; below is one charge exactly as the agent leaves it.
Intercompany charge · one service rechargeIllustrative example
Charge
Recorded as
Method
Evidence of record
Confidence
Held for
Service recharge, two jurisdictions
Documented before filing
Method file, versioned
Agreement, 6 August 2026
Held unpriced
The signing officer, by name
As receivedIn existence under 1.6662-6(d)(2)(iii)(A) before the return was filed, and producible within thirty days.
What the charge record holdsIntercompany agreementCost pool scheduleCounterparty ledger
Why no price hereSetting an arm's-length price is a judgement a named officer makes.
ActionApproveAppend documentSend for counsel review
What the score decidesBelow the configured threshold a charge gets a counsel read before the officer sees it.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Each charge raisedFrom the document that supports it
03Evidence
Where that evidence lands
The agent does not vouch for a price, only for the document behind it and the day it existed: eight of the ten principal documents must pre-exist filing, and only items (B)(9) and (10) may follow.
01Approved path
One deal, two sets of books
It is a deduction in one country and income in the other, and agreement between the two ledgers proves only that management booked one number twice.
02Human review
Looked for, and not found
No current independent measure of intercompany failure was found; the recent material is vendor-published, and the best survey located is over a decade old. The newest hard evidence is public country-by-country data: under the early Romanian regime, about a fifth of the groups in scope published.
04Build an evidence trail
The charge, the side that raised it and the officer who signed the return stay together.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Group ledgers on both sidesERP entities · subsidiary ledgers Charges raised and received
Agreements and cost poolsContract store · cost-pool data Terms and allocation keys
Transfer-pricing documentationMethod files · comparables sets Rationales and the methods set aside
Agent
Intercompany accounting
Reads both sides Drafts the charge Holds for the signer
Filings and public reportingForm 8975 · public CbCR lodgments Jurisdiction lines once published
A group-level correction figure can read clean while cross-border service charges carry most of the rework. Nestack reports the correction rate by charge class, not only across the group.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Cross-border service charges
9.8%
3.7×
Review
Cash pool positions
6.9%
2.6×
Review
Intercompany loan balances
4.3%
1.6×
Watch
Settled recharge routines
2.1%
0.8×
Normal
Bar: correction-rate lift vs. settled-recharge baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What an undocumented charge costs
A loop closes when the charge filed without its documentation is a standing case. That suite is what the next period consolidated is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on cross-border service charges.
02Diagnose
The charge that posts quietly each period and surfaces eighteen months later on a public register is worked backwards until one cause is left standing.
03Improve
Number the elimination; the charges that drove it are filed beneath it.
04Verify
A single unmatched counterparty case stops the whole consolidation.
05Learn
One case joins the suite, and one line joins the charge-out rules.
Learn → DetectThe return edge. The next charge is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, charge-out logic, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Charge classification and automation-boundary work.
02Ledger, agreement and cost-pool sources.
03Documentation and counterparty-ledger trail mapping.
04Charge and agreement intake.
05Entity, method and period binding.
06Document scoring and review routing.
07Officer approval workflow.
08Consolidation-system integration.
09Documentation and matching cases.
10Guardrails and elimination controls.
11Charge-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne entity pair, one cycleProductionProduction consolidation workflowAdvancedMultiple entities / jurisdictions
Introduced at Pilot
Charge drafting to your agreements✓✓✓
Named officer approval✓✓✓
Entity-and-jurisdiction baseline✓✓✓
Introduced at Production
Reporting by counterparty class—✓✓
Counsel review workflow in your systems—✓✓
Approved ledger write-back—✓✓
Ledger-and-consolidation integration—✓✓
Introduced at Advanced
Multi-method documentation——✓
Cross-entity charge packs——✓
Dense entity structures——✓
Multi-jurisdiction charge-out controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, entity volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your live entity pairs and the agreement each charge runs under→Agreement capture and method versioningWeek 1
02Representative agreements, cost pools and both-side ledgers→Source binding, charge-out logic and the documentation baselineWeek 2
03Your filing calendar and the officers it names→Charge-out mapping, document binding and the automation boundaryWeek 1
04Access to the relevant ledgers, feeds or exports→Ledger, agreement and cost-pool assessment, then integration setupWeek 2
05Charges you would not want published→Matching cases and the failure roundWeek 4
06What no charge may be called→Document scoring, review routing, guardrails and release controlsWeek 3
07A named officer who signs the return→Officer approval, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Week five carries two bands here because those two phases coincide, not because the column looks better.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Charge-out discovery, method versioning and the automation boundaryW2Ledger and agreement integration, and the entity-and-jurisdiction baselineW3Charge-out logic, documentation checks and release controlsW4Evaluation suite, matching cases and failure-mode testingW5Consolidation integration, pilot charges and targeted correctionsW6One filing cycle run under the tax director, then Agent Care handover
Reading the bandEach bar runs only across the weeks its own work is named for, and week five is shared by design.
At the end of W6Once the charge record validates, Agent Care picks the agent up.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Finance AI agent
Build an intercompany accounting agent around the document your last charge-out never produced.
Show us one intercompany charge you raise each period and the documentation behind it. If that file was written after the return went in, it was no defence when the officer signed. Under 7206(1) a false return is a felony; a charge nobody can document comes back as a finding.
