Epicor Transfer Pricing Case Study: Leaving the Big Four for More Efficient, Audit-Ready Global Compliance
Epicor, a global enterprise resource planning (ERP) provider, manages transfer pricing across dozens of jurisdictions for its globally distributed tax team. After years of working with a Big Four accounting firm, Epicor moved its transfer pricing documentation and benchmarking to Exactera — gaining a predictable cost structure, standardized reporting, and audit-ready documentation across 34 countries. This case study covers why Epicor made the switch, how Exactera supports its annual transfer pricing program, and what the partnership looks like in practice.
- 34 — Countries covered by Epicor’s transfer pricing documentation
- 20 — Annual transfer pricing reports managed by Exactera
- 1 — Dedicated transfer pricing partner, replacing a Big Four engagement
ABOUT EPICOR
| Company | Epicor |
| Industry | Enterprise resource planning (ERP) software |
| Customer Base | 23,000+ customers in 150 countries; 2.3M+ daily active users |
| Tax Team Footprint | Distributed across the U.S., Mexico, and India |
| Transfer Pricing Footprint | 34 countries |
| Exactera Services Used | Benchmarking analyses, master file & local file documentation, ~20 annual TP reports |
The Challenge: Transfer Pricing Complexity at Global Scale
Just as Epicor has expanded its international footprint through organic growth and strategic acquisitions, its transfer pricing obligations have grown commensurately in scope and complexity. The company’s tax team manages intercompany transactions across dozens of jurisdictions, with cost centers concentrated in Mexico and India and distribution entities operating around the world.
Will Arcentales, Epicor’s Senior Tax Manager for international matters, oversees a globally distributed team spanning the U.S., Mexico, and India. His responsibilities include U.S. and foreign compliance, transfer pricing, Pillar Two (GloBE) reporting, foreign provisions, and audit support. Managing a high volume of annual transfer pricing reports — covering master files, local files, and benchmarking analyses—demands not only technical rigor, but also a reliable, consistent service partner.
“If we had to bring all of this in-house, that would require a major investment,” says Arcentales. “We would need a system to pull the reports together, something to run the benchmarkings, and probably add additional staff—because these analyses are pretty intensive.”
Why Epicor Chose Exactera Over a Big Four Firm
Prior to partnering with Exactera, Epicor engaged one of the world’s largest accounting firms to handle its transfer pricing compliance. While that firm delivered comprehensive services, the cost structure was significant.
“Anytime you do anything with one of the Big Four in transfer pricing, it’s pretty expensive,” says Arcentales. “Our fee would have been a very different number from what we pay with Exactera.”
Epicor made the transition to Exactera several years ago, and the decision has proven durable. “I can tell you right now—if we ever went back to a Big Four firm, people would be shocked at the price tag it would come with,” Arcentales notes.
The value proposition was clear: enterprise-grade transfer pricing expertise, AI-enabled technology, and documentation at a predictable cost structure designed for companies that want best-in-class compliance without the premium overhead and mid-project cost inflation of a large accounting firm.
| Aspect | Big Four Approach (Epicor’s prior experience) | Exactera Approach (Epicor’s current experience) |
| Cost structure | High hourly advisory fees — described as “pretty expensive” | More predictable cost structure — “a very different number” |
| Reporting process | Comments and corrections often repeated across multiple reports | Standardized update template — comments captured once and applied consistently |
| Audit readiness | Available as an add-on service rather than included within the fixed fee | Audit-ready documentation included as part of the engagement—described as solid enough that “I wouldn’t be worried” under audit |
See Exactera’s Transfer Pricing Service in Action
How Exactera Supports Epicor Transfer Pricing
Exactera serves as Epicor’s dedicated transfer pricing partner, managing the full suite of annual transfer pricing documentation and benchmarking. Each year, aligned with Epicor’s September 30th fiscal year-end, Exactera delivers:
- Benchmarking analyses toestablishand validate arm’s-length pricing ranges across Epicor’s intercompany transactions.
- Master file and local file documentation for a defined set of entities, ensuring compliance with OECD BEPS guidelines and local country requirements.
- Approximately 20 transfer pricing reports covering Epicor’s global intercompany structure.
The workflow is designed to be efficient. Epicor’s team provides financial data in a standardized format, Exactera’s team takes over the analysis and drafting with their supporting technology, and reports are returned for review. Epicor’s internal team provides comments where needed, signs off, and the documentation is finalized—ready for any regulatory review or audit.
Audit Readiness: Confidence Built on Solid Documentation
Transfer pricing is inherently judgmental—reasonable people can disagree on the right arm’s-length outcome for a given transaction. What matters for audit readiness is the quality of the analysis behind the positions and the completeness of the supporting documentation.
Arcentales is confident that Epicor’s Exactera-supported documentation would hold up under scrutiny. “Transfer pricing is very subjective—anyone can have a different opinion on how things are being allocated,” he says. “But if we were ever under audit, I wouldn’t be worried. The documentation we have is solid.”
For a company operating in 34 countries with the complexity of Epicor’s intercompany structure, that confidence is not a small thing. Proper local file and master file documentation, backed by defensible benchmarking analysis, is the foundation of a sound transfer pricing posture—and the cost of getting it wrong, in the form of adjustments, penalties, and reputational risk, far exceeds the cost of getting it right.
The Partnership: Consistency, Communication, and Expertise
For Epicor, the partnership comes down to how Exactera’s team works and what they know.
“Antonela Niemiz at Exactera is very organized and very attentive to detail. She created a standardized template for how we share updates, which means comments that used to get repeated across multiple reports now get captured once and applied consistently across the board. That made a real difference,” Arcentales says.
Beyond the mechanics of delivery, Arcentales values the knowledge the Exactera team brings to the engagement. “They have a strong grasp of the substance—why benchmarkings shift from year to year, what’s changed in the global environment before and after COVID, what’s happening with BEPS and Pillar Two. That depth of understanding is important when you’re making real decisions about your intercompany pricing.”
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