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Transfer pricing

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. Visit our home page.

All publications

Transfer pricing perspectives: Re:solutions, moving towards certainty

This publication offers valuable insights and strategies on how to meet the increased transfer pricing challenges during recessionary times. Topics covered include the taxation of permanent establishments; business restructuring; implications of IFRS on cost sharing arrangements and emerging markets insights.
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International transfer pricing 2009

PricewaterhouseCoopers' International transfer pricing 2009 is an annual review which provides general guidance on a range of transfer pricing issues in 65 countries.
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Transfer pricing of intellectual property in the automotive industry: A focus on India

This report focuses on multinational business relationships within the Asian automotive industry and examines some of the transfer pricing models employed to account for the ownership and value of the intellectual property.
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Substance: Aligning international tax planning with business realities

This publication is designed to help taxpayers everywhere create—and justify—their tax plans that can deal with the increased scrutiny by tax authorities.
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Financial services transfer pricing (FSTP) perspectives

A bi-monthly publication that offers an insight into trends and developments, tax authorities’ approaches, and "hot" topic issues in financial services transfer pricing.
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Mastering the intellectual property lifecycle: 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, Mastering the intellectual property life cycle offers compelling insights from tax and legal points of view, as well as an accounting perspective.
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Transfer pricing in a recession: What companies should consider

Uncertain economic times bring both challenges and opportunities in managing transfer pricing for multinationals. This article addresses ways in which multinationals may approach transfer pricing policies, leverage benchmarking data to document present and past transfer prices, and consider strategies for existing and new Advance Pricing Agreements during uncertain economic times to optimize their ability to defend, document, and plan with respect to intercompany transactions.
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Transfer pricing and the green agenda

This article tackles key issues including the pricing of emission credits, the interaction of brands and green business policies, the effect of green spending on existing TP models, as well as the opportunities that arise as a result of environmental concern
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Transfer pricing perspectives: The emerging perfect storm of transfer pricing audits and disputes

This publication focuses on several important global dispute resolution topics, including recent developments involving the taxation of PEs, recommended improvements to APAs and Mutual Agreement Procedures (MAPs) around the world, and "best practices" in the global dispute resolution arena.
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Intellectual property in the automotive industry: Transfer pricing aspects

This paper addresses the transfer pricing principles in the context of an automotive group and compares the difference across the auto sector and other sectors.
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Production capacity management: A taxing issue

The second of a two part series on transfer pricing, transfer pricing specialists examine trends in PCM, key tax and cash considerations and PCM, managing PCM developments in practice, and the benefits of alignment in a production capacity management restructuring.
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Transfer pricing in the automotive industry: Production capacity management and transfer pricing economics

This paper examines where value exists in an organisation and reflects on some of the business and transfer pricing models used in the automotive industry.
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Transfer pricing aspects of business restructurings

This document represents a framework for a response to the invitation to comment issued on 19 September 2008. During the consultation period we will seek the views of our clients and we will submit a final, more detailed response in due course.
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Transfer pricing and IFRS

This article addresses the potential impacts that adopting IFRS accounting policies, particularly those related to revenue and expense recognition, may have on an organization's existing and future cost sharing arrangements.
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