Vela Analytics
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Transfer Pricing Analytics
Price every intercompany financial transaction to the arm's length standard
From guarantee fees to intercompany loans and cash pools — Vela guides you from transaction to audit-ready report with full OECD methodology, market benchmarks, and defensible documentation.
OECD Chapter X Compliant
Vela Sector Scorecards
Decomposed Damodaran-Sourced Yield
Basel & S&P Aligned

What does your group need to price?

Select your situation below. Each pathway guides you step by step — from transaction inputs to an audit-ready report with full OECD methodology and market benchmarks.

1
Interest Rate Benchmarks
Every intercompany loan needs an arm’s length interest rate. The right approach depends on how the loan is structured and which jurisdictions are involved. Select your situation:
Need a credit rating first? Derive one with our scorecard
Derive a rate via economic modelling
Decomposed Yield · OECD §§10.51–10.108
OECD §§10.51–10.108
Derive a rate via economic modelling
Live government yield curve + Merton-anchored credit spread + sector overlay + country premium + reduced-form liquidity + seniority adjustment + (optional) Hull-White prepayment OAS. Every input cites a public source. Indicative rating for internal use; for a fully compliant arm's-length study with comparables please get in touch.
Derive credit rating →
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Defend a rate
Special situations · audit challenge · added-fee bespoke study
Bespoke service
Defend a rate — bespoke study
Some rates are challenged in audit, are of particular commercial importance, or sit in situations where pure economic modelling doesn't provide adequate cover. For these cases, send the relevant economic factors to Jferrei3@chicagobooth.edu — happy to discuss the situation, prepare a tailored defense with full comparables, or invite you to a working meeting on the structure. Added-fee service; pricing depends on scope.
Email →
On-Lending Margin Builder
On-Lending Margin Analysis · OECD §10.100 · §7.34
OECD §10.100 · §7.34
Justify Your On-Lending Spread
External borrowing + on-lending to an affiliate. Derives the arm’s length margin with transparent cost-plus allocation and credit spread sourcing.
Derive credit rating →
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Swiss Safe Harbor
ESTV Rates · ESTV Circular
ESTV Circular
Swiss Entity? Determine Rates via Safe Harbor
If your intercompany transaction involves a Swiss entity, use ESTV published safe harbor rates to set compliant interest rates. Covers all 4 situations across 26 currencies — flags when full documentation is needed.
Launch →
2
Guarantee Fee Pricing
The guarantor assumes credit risk and must be remunerated at arm’s length. Vela brackets the defensible fee range using two OECD-prescribed methods — the Expected Loss floor and the Yield Approach ceiling.
Need a credit rating first? Derive one with our scorecard
Guarantee Fee — Audit-Ready Range
Two methods, one defensible range. The floor (guarantor’s minimum compensation) and the ceiling (borrower’s maximum benefit) together frame the arm’s-length range per OECD §§10.173–10.181. Output: 25–30 page Word report per method.
FLOOR — OECD §§10.178–10.181
Expected Loss Model
Quantifies the guarantor’s economic exposure: default probability × loss severity × capital cost. The absolute minimum a rational guarantor would require.
PD × LGD × CoE ÷ EaR
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⇄
RANGE
CEILING — OECD §§10.173–10.177
Yield Spread Approach
Quantifies the borrower's benefit from the guarantee: standalone borrowing cost minus the cost achievable with the guarantor's credit standing. The maximum a rational borrower would pay. Computed via Damodaran rating-differential spreads — no private bond database required.
Spread(standalone rating) − Spread(guaranteed rating)
Derive credit rating →
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Both reports cite OECD paragraphs, public default & recovery data, Damodaran CAPM inputs, and full sensitivity tables. The arm’s length fee lies within this range — position depends on facts and circumstances.

3
Cash Pool Allocation
Each participant needs arm’s length deposit and borrowing rates, and the synergy benefit must be allocated equitably. Vela calculates rates and splits the advantage — the analysis tax authorities expect for physical or notional pools.
Need a credit rating first? Derive one with our scorecard
Cash Pool Rate Allocation
Synergy Split · OECD §§10.109–10.148
OECD §§10.109–10.148
Allocate Cash Pool Benefits at Arm’s Length
Calculate deposit and borrowing rates per participant. Quantify the synergy advantage and allocate equitably. Multi-currency support with live FX. Output: audit-ready documentation.
Launch →

Governance & Risk Infrastructure

The analytical backbone behind every pricing decision. Credit assessments, entity profiling, compliance monitoring, and profit allocation — all integrated into the same platform.

Credit Rating Scorecard
Vela Scorecard · OECD §§10.62–10.82
OECD §§10.62–10.82
Derive a Defensible Credit Rating
Transparent credit assessments using Vela’s own sector scorecards. Includes S&P-style group rating, SPV LTV analysis, and audit-ready Word report.
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Entity Functional Profile & Contract Drafting
FAR Analysis · OECD Ch. I & IX
OECD Ch. I & IX
Characterise Entities, Draft Defensible Contracts
Assign each entity its OECD functional archetype, see guaranteed returns vs. residual profit, and generate intercompany agreements with the correct clause library per relationship.
Launch →
TP Compliance Monitor Draft
Risk Dashboard · OECD Ch. IV · Draft
Draft
Spot Documentation Gaps Before Auditors Do
Track every intercompany transaction, credit profile, and compliance position across jurisdictions. Flags policy misalignment and pricing outliers at a glance. This module is an early draft — outputs are indicative and still being hardened.
Open draft →
Enterprise Valuation
FCFF DCF · Damodaran inputs
Intrinsic value
Value a Business from its Cash Flows
Project 1–3 years of financials onto industry data, discount Free Cash Flow to the Firm at the WACC, and read off enterprise and equity value. Fully editable like a game, with a multiples football-field cross-check and a history-based reality check. A defensible starting-point valuation.
Launch →
CbCR Analyser
Substance Alignment · OECD BEPS Action 13
Coming soon
Country-by-Country Alignment Check
Identify misalignment between reported profits and economic substance across jurisdictions. Pre-empt BEPS-driven audit triggers.
Coming soon
DEMPE Value Chain Mapper
IP Attribution · OECD Ch. VI
Coming soon
Map IP Value Creation Across Entities
Identify which entities perform DEMPE functions and whether profit attribution aligns with substance.
Coming soon
ESG & Sustainability Impact
Green Pricing · OECD Pillar Two
Coming soon
Quantify ESG Impact on TP Policies
Assess ESG factors and their impact on credit assessments and TP policy. Aligned with Pillar Two and EU taxonomy.
Coming soon
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Rating methodologies
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Countries covered
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Industry sectors covered
Since 2020
Analysis data available

Built for enterprise TP teams, not spreadsheets

Excel models break silently, lack audit trails, and don't scale across jurisdictions. Vela replaces fragile internal spreadsheet tools with methodology-grade infrastructure that withstands tax authority review.

Legal Defensibility

Every output cites the exact OECD paragraph, data source, and methodology step. Reports are structured for tax authority review — not internal consumption.

25–30 page Word reports · OECD §-level citations · sensitivity tables · data source appendix · full audit trail per analysis

Jurisdiction Coverage

178 countries, 26 currencies, Swiss-specific ESTV safe harbor logic, and multi-jurisdiction compliance monitoring. One platform for your entire group.

ESTV Circular · Basel III alignment · Vela 22 sector scorecards · S&P-style group rating · Damodaran country risk premiums

Methodology Depth

Not a black box. Every calculation is transparent: spread-implied PD, Basel supervisory recovery rates by seniority, CAPM with Damodaran inputs, and IQR-based comparable analysis.

Public default data · Basel BCBS Foundation-IRB LGD · Damodaran default spreads & sector betas · Merton structural model · S&P-style borrower status framework

Output & Integration

Export audit-ready Word reports, Excel working papers, and structured data. Every analysis is versioned with timestamp, inputs, and methodology — ready for your documentation file.

Word (.docx) · Excel (.xlsx) · structured JSON API · versioned analysis history · team multi-user access

From input to audit-ready output in three steps

No black boxes. Every step is transparent, documented, and defensible.
1
→

Define the transaction

Enter the intercompany transaction details — or upload financial statements directly. Vela derives all required ratios, validates inputs against sector benchmarks, and flags inconsistencies before you proceed.

2
→

Apply the methodology

Vela selects and applies the OECD-prescribed method for your transaction type: Expected Loss for guarantees, CUP for loans, ESTV safe harbor for Swiss entities. Every assumption is sourced and adjustable.

3

Export documentation

Receive the arm's length price with a 25–30 page Word report: full methodology, sensitivity analysis, OECD paragraph citations, data source appendix, and audit trail. Submit-ready for any tax authority.

Built on authoritative data

Every calculation is grounded in recognized, defensible sources

Public default & recovery data

Spread-implied PD + Basel supervisory recovery by seniority

Vela sector scorecards

20+ Vela-original sector scorecards with calibrated thresholds and weights

Damodaran

ERP, equity betas, country risk for 178 countries

Central Banks

Risk-free rates from ECB, Fed, BOJ, BOE, MAS, SNB

OECD Guidelines

Chapter X (Financial Transactions), §§10.51–10.188

Damodaran & Merton

Default spreads by rating, sector betas, structural credit overlay

Transparent pricing

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