Global Core Documentation

Global Core Documentation™

As multinational corporations (MNCs) continue to expand on a global basis, cross-border transactions (e.g., the sale of goods, the provision of services, the lending of funds, the licensing of intellectual property, etc.) between affiliates also continue to grow in frequency and complexity. As a result, MNCs are increasingly becoming subject to transfer pricing requirements in many jurisdictions resulting in an expansion of the obligations being imposed on the MNC's taxpayers by their governments.

PKN alerts
The PKN provides alerts apprising you of the impact of major transfer pricing, tax, and related developments within hours of news breaking.
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Transfer pricing in the news
News and views from PwC's Transfer Pricing practice with articles covering the significant transfer pricing developments impacting your company.
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Transfer pricing publications
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The Global Tax Monitor
The Global Tax Monitor¹ recognises PricewaterhouseCoopers as the leading firm globally for transfer pricing, by reputation, with a very strong lead over the competition. These results are based on the year-ending Q2 2009 figures, with a sample size of 3,246 primary buyers of tax services globally.
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Working with PricewaterhouseCoopers

An efficient and consistent framework for producing the required level of documentation is required to defend transfer pricing practices and results of an MNC. PricewaterhouseCoopers' Transfer Pricing practice has developed the Global Core Documentation (GCD) service offering designed to assist MNCs in developing coordinated global transfer pricing documentation. It enables clients to determine where to focus efforts and deploy resources to satisfy the specific local-country requirements of client-selected tax authorities around the world without losing consistency.

The GCD philosophy is to centrally collect common data and background information that can be shared among the countries that require documentation. A GCD project involves the centralised preparation of a "core" document as well as local documentation package that is used by each country that requires transfer pricing documentation. PwC’s GCD allows different levels of documentation for different situations. This process facilitates the efficient preparation of separate country reports that satisfy each country's specific documentation requirements in a globally consistent framework.

Value to your company

In addition to requiring compliance with local transfer pricing rules, tax authorities are escalating audit/inspection activity related to transfer pricing. Moreover, the number of jurisdictions imposing strict penalties for failure to comply with transfer pricing documentation requirements is growing. In the face of the increased fiduciary and legal responsibilities to comply with specific transfer pricing documenation requirements of multiple tax jurisdictions, the need for more efficient and consistent transfer pricing documentation is paramount.

¹ TNS Global Tax Monitor data, Q2 2009. The Global Tax Monitor is a multi-client independent survey of more than 3,000 key tax decision makers per annum (CFOs and Tax Directors) in 31 key markets worldwide.