Transfer pricing is a term used to describe all aspects of intercompany pricing arrangements between related business entities, including transfers of intellectual property; transfers of tangible goods; services and loans and other financing transactions.
Inter-company transactions across borders are growing rapidly and are becoming much more complex. Compliance with the differing requirements of multiple overlapping tax jurisdictions is a complicated and time-consuming task.
At the same time, Tax Authorities from each country are imposing stricter penalties, new documentation requirements, increased information exchange and increased audit/inspection activity.
If this is your situation
- You need advice on transfer pricing documentation requirements in multiple jurisdictions.
- You are uncertain whether an Advance Pricing Agreement is a better option than defensive documentation.
- You need to respond to a tax authority transfer pricing audit / enquiry.
- You are interested in "best practices" for managing your worldwide transfer pricing policies and procedures.
- You need to know whether your internal controls over transfer pricing are sufficient to satisfy a Section 404 end of year audit.
How PwC can help you
Our transfer pricing specialists have advanced training in economics, accounting, law and project management. Our specialists include numerous partners and staff with experience gained with tax administrations. We can advise you on: