# Who can license intercompany records? Decision tree

Canonical: https://refer.sourcex.si/questions/who-can-license-intercompany-reconciliation-records
Last updated: 2026-10-19

Start with the group controller, who knows where intercompany records sit and what they mean, then introduce the officer who can authorize a licensing discussion for every entity whose records are involved: the group CEO, with a subsidiary's own CEO where that subsidiary signs for itself. Running the close is not authority to license. Counsel decides which entity holds rights to each record, and that answer stays open until SourceX's rights review.

This decision tree is part of the [intercompany reconciliation guide](/guides/workflow-intercompany-reconciliation). It takes a fractional CFO from the first conversation to the right introduction in six questions. It is general information, not legal advice.

## Why one company's answer does not work for a group

In a single company, one officer can usually speak for all its records. In a group, the records of a single intercompany transaction are split by design: the seller's entry belongs to the seller, the buyer's entry to the buyer, and the reconciliation and elimination are often kept by the parent or a shared-services team.

IFRS 10 frames the structure: a group is a parent and its subsidiaries, a parent is an entity that controls one or more entities, and a non-controlling interest is the equity in a subsidiary that the parent does not own. Control explains why the group CEO can usually sign for the group. Non-controlling interests explain why a partly owned subsidiary may need more than that. The page on [which entity owns data in a holding company structure](/questions/which-entity-owns-intellectual-property-holding-company-structure) explains the ownership test in more depth.

## The yes path, question by question

Answer in order. Each answer either moves you toward a signer or adds a reviewer.

| Question | If yes | If no or not sure |
|---|---|---|
| 1. Does one shared ERP instance hold every entity's intercompany entries? | Find out which entity owns the instance; go to 2 | Each entity's ledger has its own owner; list them; go to 2 |
| 2. Does an intercompany or shared-services agreement say who owns records the shared team creates? | Counsel reads it; go to 3 | Mark "unknown" for the rights review; go to 3 |
| 3. Are all involved subsidiaries wholly owned? | The group CEO signs; go to 4 | Outside shareholders may need to be considered; the subsidiary's CEO signs, with counsel checking any shareholder consent; go to 4 |
| 4. Are any involved entities in another country? | Note each country for eligibility and local law; go to 5 | Go to 5 |
| 5. Do approvals and notes name individual staff? | Note it; de-identification may be needed; go to 6 | Go to 6 |
| 6. Will the named officer take a short call? | Introduce them, with the controller as sponsor | Do not submit yet; ask the controller to raise it with the CEO |

Most wholly owned domestic groups stop at question 3 with the group CEO. Groups with partly owned or foreign subsidiaries take longer branches, and [whether you can refer a foreign-owned U.S. company](/questions/can-i-refer-a-foreign-owned-us-company) covers one common variant.

## Who holds which records, and who can approve

| Role | What they can tell you | Can they authorize a data discussion? |
|---|---|---|
| Group accountant | Volume of reconciliation items, reason codes in use, where workbooks sit | No |
| Group controller | Systems, years of coverage, mapping versions, retention rules | Rarely; the natural sponsor |
| Entity finance lead | That entity's ledger, its intercompany entries and approvals | No |
| Group CFO | Whether the group would consider a discussion; prepares the case | No; the CEO signs |
| Group CEO, or a subsidiary's CEO | Final approval for each licensing entity | Yes, within its own entity |
| Counsel | Which entity holds rights; agreement and privacy limits | No; advises on ownership and terms |

Many mid-size groups use outside finance leaders. The [holding company CFO page](/for/holding-company-cfo-responsibilities) describes the typical remit, and [whether a fractional CFO can sign for a company](/questions/can-fractional-cfo-sign-contracts-behalf-company) covers outside finance leads.

## Where counsel, minority holders or staff data come in

Three questions belong to counsel rather than to the partner.

**Records created by a shared team.** When a parent's shared-services team reconciles every entity, the workbooks may belong to the parent even though they describe subsidiaries' transactions. The intercompany agreement, if it says anything, decides. [Who owns data in a shared group system](/questions/who-owns-data-in-a-shared-group-system) sets out the usual reasoning.

**Partly owned subsidiaries.** Where outside shareholders hold part of a subsidiary, licensing its records may need that subsidiary's own board approval, and counsel will look at its shareholder agreement.

**Staff in the trail.** Approvals and reconciliation notes name the people who made each decision. Under the EU General Data Protection Regulation, personal data is any information relating to an identified or identifiable natural person, including by reference to a name or identification number, and comparable rules apply elsewhere. SourceX's review decides what de-identification is needed.

System history can matter too. NetSuite's setup guidance says Automated Intercompany Management needs elimination subsidiaries and cannot be disabled once enabled, so groups using it carry elimination records owned by an entity created only for that purpose. Counsel may want to know which entity that is. [Why data rights matter](/proof/why-data-rights-matter) explains why these questions come before any buyer conversation.

## What the tree cannot settle before SourceX's rights review

The tree tells a partner whom to introduce. It leaves these open:

- which entity holds the right to license each record class
- whether intercompany or shareholder agreements restrict any records
- what staff de-identification is needed
- whether there is buyer interest in the group's reconciliation history, and on what terms

For SourceX, an introduced company needs 50+ full-time employees at peak (contractors excluded), a documented operating history, rights to license and an authorized contact. Companies in the U.S., Canada and the EU qualify, as do companies in the UK, Australia, New Zealand, India, Singapore, South Africa, Latin America, the UAE and Saudi Arabia when at least 90% of the data is in English. Partners sign the Channel Partner Agreement before submitting introductions, and never ask for ledgers, workbooks or logins. The [referral brief template](/resources/intercompany-reconciliation-referral-brief-template) has a field for the signer, and the [system map](/guides/intercompany-reconciliation-records-across-systems) shows which system each owner controls.

## Next step

> **Refer a company. Earn up to $100,000.** Default reward: 25% of Actual Supplier Payout, capped at $100,000 cumulatively per referred company. Eligibility and payment conditions apply, and a signed Schedule A or addendum can differ. A lead, meeting or signature alone does not trigger payment.

Once the tree has named the officer who can speak for every entity holding the records, [register as a partner](/register), check the group against [who qualifies](/who-qualifies) and read the [program terms](/terms) before the controller makes the introduction.

## Sources

- https://www.ifrs.org/content/dam/ifrs/publications/html-standards/english/2022/issued/ifrs10.html
- https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng
- https://docs.oracle.com/en/cloud/saas/netsuite/ns-online-help/section_N1486610.html
- https://refer.sourcex.si/terms