Transfer pricing publications

Cross-border transactions are growing rapidly and compliance with the differing requirements of overlapping tax jurisdictions is a complicated and time-consuming business. At PwC we have a strong international network of dedicated transfer pricing professionals ready to work with you.

Transfer Pricing Perspectives - The new normal: full TransParency

A series of articles based on our sessions at our recent Global Transfer Pricing Conference in Toronto, Canada.

TP Talks podcast series

PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts not only provide you the latest regulatory changes and developments, but also inform you how they can impact your business.

Tax Analyst article: Final BEPS guidance renews emphasis on intercompany agreements

In this article, the authors discuss how the OECD’s final report on transfer pricing documentation and country-by-country reporting will affect how multinational enterprises handle intercompany agreements.

International Transfer Pricing Book

International Transfer Pricing 2015/16, now in its 15th edition, is an easy-to-use reference guide covering a range of transfer pricing issues in nearly 100 countries worldwide.

Tax insights from transfer pricing

These alerts provide analysis of the impact of major transfer pricing, tax, and related developments within hours of the news breaking, authored by PwC professionals around the world. Each alert is classified by the country or territory to which it pertains.

India Transfer Pricing Survey - You said it!

The report summarises views of over 160 senior executives representing various Indian and foreign multinational enterprises across the country.

An interview with Pascal Saint-Amans, Director of the OECD's Centre for Tax Policy and Administration, on base erosion and profit shifting (BEPS)

Understand OECD BEPS project and Discussion Draft on country reporting & transfer pricing, improved dispute resolution, impact of harmful tax & more. Watch.

Base Erosion, Profit Shifting and the Future of the Corporate Income Tax

In this article for Bloomberg BNA, David Ernick discusses the potential implications of the OECD BEPS initiative on corporate income tax.

Progress, but no guarantees for the consistent treatment of intercompany financing transactions

Expect more attention to be paid to your arm’s-length pricing and their tax treatment, from both tax authorities and financial statement auditors.

Regulatory reform in the financial industry and end-to-end transfer pricing execution

Article looks at how financial institutions are increasingly integrated in a globalised world and so must tighten their controls, processes and governance policies.

This article looks at how you can deal with the many challenges of international expansion

This article looks at why carefully coordinated actions and informed strategies are needed now before the next wave of tax audits and disputes rolls in.

Transfer pricing for industrial products companies

What are the transfer pricing and supply chain implications of mergers and acquisitions for industrial products and services companies? PwC explores the trends.

Transfer pricing symptoms of chronic industry challenges

This article lays out these and other key issues you may be facing, and offers guidance on how to bring your transfer pricing strategies up to date - while managing the expectations of multiple stakeholders.

South America: Dealing with local complexity when applying global transfer pricing policies

In this article we show why you must exercise special care when returning to central marketing or sourcing entities, or when applying royalties or shared services agreements.

Value Chain Transformation Globalisation Maturity Framework

This article looks at how you can deal with the many challenges of international expansion

The politics of taxation

This article looks at the criticism and perceived shortcomings of the current system, its potential alternatives, and policy developments to date -- and draws a strong conclusion: act now before it’s too late.

Double jeopardy…Leading practices for managing double taxation risk in the oil and gas industry

In this article, we take a closer look at some of the particular regulatory and tax issues you will face - and offer best practices to help you navigate them.

The impact of transfer pricing on real estate funding – Mezzanine financing

In this article we take an in-depth look at the issue in key jurisdictions - the US, UK and Japan - and offer suggestions on how you can increase the robustness of your transfer pricing policies around real estate financing.

Russia’s new rules: Overview and practical aspects

This article summarises the significant changes, the new rules, and their practical aspects for any multinational with operations in Russia.

The intersection of enterprise resource planning (ERP) systems and transfer pricing

This article takes a close look at how your ERP systems and transfer pricing policies interact - and offers some best practices for avoiding the downside of your growth upside.

Industrial manufacturing: Mexico Maquila BEPS scrutiny: PwC

In addition to measures proposed in the tax bill presented last September 8th the new head of the Large Taxpayer section of the SAT (Oscar Molina) announced that Mexican authorities have started taking specific actions on Base Erosion and Profit Shifting (BEPS) under a pre-defined action plan, through including anti-avoidance measures in respect of maquila and other business restructurings.

Tax Controversy & Dispute Resolution: OECD White Paper on Transfer Pricing Documentation proposes coordinated approach based on a two-tier structure

The OECD White Paper on Transfer Pricing Documentation looks to harmonise TP documentation, and proposes a Coordinated Approach based on a two-tier structure.

Tax Controversy & Dispute Resolution: OECD project on intangibles: Revised Discussion Draft released

Additional guidance on how to correctly allocate the return related to an intangible location

Permanent establishments 2.0: The heart of the matter

This publication provides an overview of some of the main trends which can be identified on the topic of permanent establishments.

Substance 2.0: Aligning international tax planning with today's business realities

This publication provides an overview of some of the main trends which can be identified on the topic of permanent establishments.

Navigating the complexity – Findings from a financial transactions transfer pricing global survey

This PwC survey offers general guidance on a range of inter-company financial transactions-related transfer pricing issues and helps tax professionals navigate these complex laws in over 40 countries.

Transfer Pricing to Go - Download our new App now

TP to Go is a new mobile application from the PwC global transfer pricing network that brings the best thought leadership from the network directly to your current smart phone. TP to Go is free to download on iOS, Android, and BlackBerry.

Clarifying the rules: Sustainable transfer pricing in the financial services sector

This PwC reference guide helps you manage your financial services transfer pricing issues.

Mastering the Intellectual Property Life Cycle: A global perspective on the tax-efficient management of IP rights

Organised in a way that systematically mirrors the actual life cycle of IP rights, PwC's new book, Mastering the intellectual property life cycle, offers compelling insights from both tax and legal points of view, as well as an accounting perspective.