Does GSA consider intra-company work transfers a "commercial sale"?

Internal sales are likely a different class of customer on your CSP. The Basis of Award and Price Reduction are probably not tied to this class of customer. However, if these sales were included on the CSP for the class of customer that is tied to your BoA and Price Reduction, then your stuck with it.

I wish our CSP was that detailed. Our class of customer is simply "all commercial customers". Our division really doesn't have commercial products or services, so all of our business is either with the Fed Govt or federal systems integrators. The systems integrators are our "commercial customers' as I read it. I feel like there is a gray area regarding selling services to another division in our company which is reselling them to either a federal govt customer or a commercial company. I am trying to determine if that is a commercial sale and I am coming-up empty on GSA publications.

Appreciate any pointers you might have.

Did you distinquish between Direct (sales directly to a customer) and Indirect (sales made through a reseller or other prime contractor) sales on your CSP?