The moment a company operates in more than one country, it must address transfer pricing. This term describes the price at which related companies within the same business group charge one another for services, development, use of intellectual property, or sales activity. On the surface, it sounds technical. In reality, it is one of the most sensitive areas where money, tax planning, and strategy intersect.

At first, transfer pricing feels like an administrative solution. You need to assign a price to R&D in Israel, a commission to sales in the United States, management fees between entities. Something that simply needs to be “in order.” But this is where the mistake begins. A transfer price is not just a number. It is a clear statement about where value is created within the company, where the IP is located, who bears the economic risk, and where profits should be recorded. Because there is always a moment when a tax authority conducts a review and examines the assumptions underlying the model.

In 2026, those questions arise quickly. Today, more than ever, there is extensive information sharing between tax authorities, deeper due diligence processes, and investors who understand that transfer pricing is a direct reflection of the business model. Transfer prices that were set without thorough analysis become a weak point precisely at critical moments: a funding round, a restructuring, or an exit.

Preparing a proper Transfer Pricing Study to determine how intercompany transactions should be structured, including the appropriate model, changes the picture entirely. It forces management to pause and answer fundamental questions: Who truly creates the intellectual property? Who bears the economic risk? And how should this be reflected in the numbers? This is not merely an accounting exercise. It is a process that connects finance management, strategy, and taxation, building one coherent and defensible financial narrative.

Companies that invest in preparing their transfer pricing framework discover that it stops being a source of concern. Instead, it becomes a management tool that protects the company and allows it to grow without fear of the next question.

At Danoy, we support companies throughout this exact process. Our experience in transfer pricing comes from hands-on finance department management and real multinational operations. We lead in-depth work that builds a financial story you can stand behind over time. If your company operates in multiple countries and conducts intercompany transactions, meaning money moves across entities within the group, this is the moment to ensure your numbers tell the right story.

Would you like to be covered with transfer pricing that truly works for you? Talk to us.