Transfer pricing

Fast-moving changes and significant regulatory developments

The stakes are high

The factors driving intensified scrutiny of transfer pricing arrangements are beyond the control of most companies, but the risks to your organisation are very real. They include:

  • very large local tax reassessments -- with significant penalties and interest on overdue tax – and double taxation on income when relief under tax treaties is not available;
  • uncertainty about your worldwide tax burden, and expensive, time-consuming conflicts with regulatory authorities;
  • damage to reputation and corporate brand if seen as a bad corporate citizen.

Our global presence

With over 3,100 transfer pricing professionals deployed in more than 90 countries, we’re well positioned to advise you on developing compliant, tax-efficient structures that help advance your business goals.

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PwC’s Global Coordinated Documentation™ (GCD)

How to cope with the increased transparency and disclosure requirements? You need an efficient, consistent framework to produce the documentation required to defend your transfer pricing policy. You need to know where to focus your efforts efficiently. And you need to ensure all specific local-country tax authority requirements are met consistently among territories. Our GCD service helps with it all.

Our GCD offerings can help you:

  • analyse the potential implications of these new requirements and identify remedial actions to take prior to implementation
  • prepare the Master File and ‘core’ Local File utilising the GCD concept ( ‘core’ document to then be used by each country as part of its Local File report deployed wherever you do business)
  • analyse the output of your country by country report, including identifying how any risks could be addressed
  • review consistency of disclosures with the Master File, Local File and local information returns

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Country by country reporting

  • The final guidance from the Organisation for Economic Co-operation and Development (OECD) expects country by country reporting (CbCR) data on transfer pricing documentation for fiscal year beginning on or after 1 Jan 2016 to be available by end of 2017.
  • CbCR will require multinational enterprises (MNEs) to provide information on their global allocation of profit, taxes paid, and certain indicators of economic activity among the countries in which they operate (by end of 2017).
  • CbCR may cause significant challenges to businesses, so many companies are planning their response to CbCR now. Engagement at Board level early on and your organisation’s ability to comply with such detailed data requests will be critical.

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Financial services transfer pricing

What we offer:

  • Global presence
  • Strong record of cross-border collaboration
  • Knowledge and insights of evolving regulatory landscape driven by organizations like the OECD, European Union, UN, and other stakeholders, with advice addressing specific policy impacts for the financial services sector around regulatory developments in all major theatres
  • With respect to Financial Services Transfer Pricing (TP), the team is actively engaged in thought leadership and providing pragmatic advice for sector-specific intercompany issues across each of the financial services sectors, including, for example, transfer pricing issues surrounding management company structures across traditional, alternative, or private equity Asset Management groups; proportional or treaty-based risk ceding transactions, and risk support or other services transactions for Insurance groups; as well as trading services, booking models, services, and other intercompany issues for Banking and Capital Market participants.
  • With respect to Financial Transactions TP, the team understands the ambiguity in the arena due to the absence of direct regulatory guidance with respect to such transactions, and has successfully developed technically robust and implementation ready support across the wide variety of instruments and operations that are impacted by financing and related treasury transactions across a multinational organization. The team includes specialists in all key markets with deep technical and controversy experience covering the entire spectrum of intercompany treasury transactions, including loans, guarantees, cash pooling

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Advance pricing agreements

As tax controversies increase globally, companies are facing even more challenges to mitigating tax risk and achieving tax certainty. Advance pricing agreements (APAs) remain a potent tool for achieving those goals. Learn how PwC and our global network of transfer pricing and tax controversy professionals are ready to help you successfully navigate the APA environment.

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Value chain analysis

Whether it’s explaining the profit profile of your country by country reporting, evaluating the resilience of your transfer pricing generally, or testing the application of specific methods, it’s much more important now to identify which activities in your business generate value and how profits get allocated.

Increasingly people are turning to Value Chain Analysis (VCA) to meet these needs and the OECD has devoted a significant part of its treatment of the profit split method to distinguishing the roles of VCA, which is more general, and profit split, which is the application of a specific TP method.

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End-to-end transfer pricing

Examining your organisation’s internal functions and procedures? The benefits of a more strategic E2E transfer pricing execution can be widespread and long-lasting. These include:

  • Meeting statutory requirements more quickly; improving compliance, transparency, efficiency and communication
  • Reducing audit risks, indirect tax compliance costs, and costs of audit defence
  • Maintaining better internal tax controls
  • Developing a faster close process
  • Standardising data collection processes and transfer pricing calculations
  • Improving cash tax management
  • Performing efficient transfer pricing scenario analysis  

PwC’s transfer pricing professionals can help you reinvent your E2E strategy and processes, leading to a more streamlined approach, reduction in workload, increased accuracy of charges, significantly enhanced transparency, and - not least - well-positioned documentation to support future reviews, including local statutory audits.

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Value chain transformation

Value Chain Transformation (VCT) is part of PwC’s Integrated Global Structuring umbrella solution set. VCT is dedicated to helping our clients align compliant tax strategies with business initiatives and operating models. This is a particularly critical task in light of OECD BEPS and related initiatives.

VCT solutions span across different industry sectors and different parts of the value chains – from supply chain, innovation, marketing and sales, logistics, global business services, etc. VCT operates as a network of specialists from our International Tax Services, Transfer Pricing, Customs and Trade, and Advisory practices.

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Contact us

Isabel  Verlinden

Isabel Verlinden

Global Transfer Pricing Leader, PwC Belgium

Tel: +32 (0)2 710 44 22

Horacio Peña

Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817

Jeff Yuan

Jeff Yuan

Asia Transfer Pricing Leader, PwC China

Tel: +86 21 2323 3495

Lorenz Bernhardt

Lorenz Bernhardt

EMEA Transfer Pricing Leader, PwC Germany

Tel: +49 1755842359

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