How Jaggaer Managed Transfer Pricing Complexity Across 17 Countries After Rapid M&A Growth

ABOUT JAGGAER

The Challenge: Managing Transfer Pricing Compliance After Rapid M&A Expansion

When Jaggaer’s Global Director of Tax Angela Griffin took stock of the company’s transfer pricing position, what she found was daunting. In under five years, Jaggaer had expanded from a straightforward US business into 17 countries across Europe, the Middle East, Asia Pacific, and the Americas — almost entirely through mergers and acquisitions. She was the only person in the tax department.

The M&A activity had created a complex web of intercompany arrangements — many of which had never been documented, and some of which had never even been identified as transfer pricing transactions. At the same time, workforce migrations across jurisdictions were creating new compliance obligations that executives outside the tax department had no awareness of. Griffin had to identify every arrangement, document it to a standard that would withstand scrutiny in a post-BEPS world, and build a compliant group-wide transfer pricing structure from the ground up.

The Big Four were not an option — the budget simply did not allow it. She needed an expert team, a technology-driven approach, and she needed to move fast.

Griffin found herself in a race against the clock. Many transactions hadn’t been documented at all and she found a host of arrangements that hadn’t even been identified as transfer pricing transactions. “I discovered we had cross charges that we didn’t consider in our IP transfer pricing planning. We had intercompany loan arrangements, various service type transactions ranging from customer service, implementation, management type services, and then we realized we had other intercompany service transactions not previously identified in any agreement,” she says.

Why Jaggaer Chose Outsourced Transfer Pricing Over the Big Four

The scale of what needed to be identified and documented was significant. As Griffin describes:

“I discovered we had cross charges that we didn’t consider in our IP transfer pricing planning. We had intercompany loan arrangements, various service type transactions ranging from customer service, implementation, and management type services — and then we realized we had other intercompany service transactions not previously identified in any agreement.”

Jaggaer needed an efficient, knowledgeable transfer pricing team and found it at Exactera. “They are transfer pricing experts and I loved their breadth of knowledge,” says Griffin.

This was not a job for one person working alone. Jaggaer needed a transfer pricing team with the breadth of knowledge to identify what others had missed, the technology to document it quickly, and transparent fixed-fee pricing that fit within budget constraints. They found all three at Exactera.

Unlike the Big Four, Exactera charged a single lump sum covering all of Jaggaer’s transfer pricing — including new arrangements identified along the way — with no hidden fees. “When we needed additional benchmarking for new transactions Exactera was able to help provide at no additional cost,” says Griffin.

What stood out most was how invested the Exactera team became in understanding Jaggaer’s business. “They are transfer pricing experts and I loved their breadth of knowledge. Exactera made efforts to get to know our company. The economists talked through our transfer pricing planning and questioned it instead of just accepting what we gave them. It was almost like a second review.”

Automating Transfer Pricing Documentation Across Multiple Jurisdictions

With dozens of intercompany arrangements to document across tight and varying country deadlines, manual processes were never going to be sufficient. Jaggaer used Exactera Transfer Pricing software to streamline the entire compliance process — transactions requiring fresh benchmarking searches using ExactMatch were completed in seconds rather than days. Exactera’s economic experts also advised on country-specific preferences that are rarely documented anywhere, ensuring nothing was missed.

Rather than managing the software in-house, Jaggaer chose to fully outsource benchmarking and compliance documentation to the Exactera team — giving Griffin complete coverage across every jurisdiction without adding headcount.

“We needed to ensure that the company has accurate, defendable positions that are documented well in all countries where we had operations — and we needed a comprehensive plan for the whole company,” says Griffin.

Navigating Country-Specific Requirements and Language Barriers

Every country in Jaggaer’s structure had its own documentation deadline, its own unstated local preferences around transfer pricing methods, and its own interpretation of tax terminology. What meant one thing in one jurisdiction meant something different in another — and getting it wrong was not apparent until year-end.

“The language barrier has hindered communication and understanding of proper categorization, especially for the various types of intercompany services. That’s how we get incorrect markups that are not apparent until year-end,” says Griffin.

Exactera’s local specialists bridged that gap directly. For Italy — one of Jaggaer’s more complex jurisdictions — having a native-speaking expert on hand made a measurable difference.

“We’ve utilized Exactera’s Italian specialists for the formatting of the reports in Italy. When we have unique transactions it helps to have someone who speaks Italian to discuss the local requirements and comfort our local employees on the accuracy of our reporting,” says Griffin.

Managing Complex IP and Intercompany Service Transactions with Expert Support

Two of the most highly scrutinised transaction types by tax authorities are IP arrangements and intercompany services — and Jaggaer had both in significant volume across unfamiliar jurisdictions. Griffin needed expert guidance not just to document these transactions but to identify which ones were most likely to attract scrutiny.

Exactera’s economic experts advised on the complex transactions, flagged those most likely to be under the microscope, and helped Griffin build the knowledge to manage them confidently going forward. Through Exactera’s webinars, Griffin deepened her own understanding of transfer pricing — and brought other staff members including Jaggaer’s controller along with her.

For transactions requiring fresh benchmarking, Griffin had a full team to collaborate with for the first time. “When we’ve had issues that required benchmarking, we were able to ask a lot of questions without incurring additional fees.” Together the team established agreed-upon terminology across transaction types — a vocabulary Griffin was then able to share with Jaggaer’s financial controllers to keep the entire group aligned.

The Results: Audit-Ready Transfer Pricing Compliance in 17 Countries

Exactera was able to help identify and produce documentation for the continuously growing Jaggaer, so the company’s transfer pricing is in compliance all over the world. Plus, now Jaggaer has a process in place that streamlines compliance and makes it a slick operation throughout the group.

Griffin feels much better about the company’s transfer pricing position. “I feel more confident now that our transfer pricing documentation has been prepared,” she says. “Exactera has saved me lots of time. I didn’t have the experience or time to create these documents myself, especially in such a short timeframe. Exactera helped us be compliant. Given our sudden growth, we wouldn’t have been able to be compliant without tax technology.”

Had she gone with traditional consultants, the cost would have been exorbitant. As Griffin said, “Exactera has given us a lot of bang for our buck.”

Managing transfer pricing compliance across multiple jurisdictions after an acquisition? Speak to an Exactera transfer pricing expert today!