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Multinational companies operate in an increasingly regulated environment. International standards supported by OECD countries have set the tone for increased transparency, documentation, and disclosure through Country-by-Country (CbC) reporting under the Base Erosion and Profit Shifting (BEPS) project. These initiatives require companies to report information about their operations across multiple jurisdictions and consider their transfer pricing methodologies and risks. Even with the right record-keeping and support, tax audits over transfer pricing can still occur. To mitigate risks in this environment, it is advisable for taxpayers to undertake an analysis of their transfer pricing arrangements and maintain appropriate documentation. In addition, entering an advance pricing agreements, when available, can be an effective measure for reducing future transfer pricing tax risk. These efforts can require significant resources for companies that operate in multiple jurisdictions.
PwC’s Transfer Pricing Team can assist clients with their transfer pricing needs. Our team members have extensive training and experience in working in this area, from helping clients navigate the new CbC requirements to crafting reliable and accurate transfer pricing studies. The global network of PwC member firms is also ready to assist clients with localized needs.