Transfer Pricing

Taking you from fast-moving complexity to a competitive business advantage

Transfer pricing is a complex area for any business. Changes are fast-paced and regulations are constantly shifting around the world. All organisations are under intense scrutiny. We work with you to overcome the complexity and help you achieve your business goals.

More clarity. Greater confidence

When it comes to global transfer pricing, you’ll need support to help you turn complex and changing regulations into a strategy for success.

We have more than 4,000 people in more than 100 countries around the world, ready to support you. Together, we’ll develop a compliant, tax-efficient structure that helps you achieve your business goals. We can help you embrace the opportunities offered by cooperative compliance in terms of effective corporate governance and internal controls for TP matters - which results in close cooperation between tax authorities and corporate citizens. We can help to tell your story right through convincing documentary evidence* on how the overall system profit is allocated across the value chain and country borders. World is pushing us into new models for addressing the issues in advance and solutions that are technologically efficient, consistent and coherent. Our current analytics capabilities and our emerging TP technologies will serve as a powerful basis for your needs such as TP workflow management and automated tasks. In this way, we’ll help you get more certainty about your worldwide tax burden, and avoid expensive, time-consuming conflicts with regulatory authorities. And we’ll help you make sure your reputation stays intact and that the world sees you as a good corporate citizen.

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PwC’s Global Coordinated Documentation™ (GCD)

Today, your business faces demands for increased transparency and greater disclosure requirements. That means you’ll need an efficient, consistent framework for producing the documentation that defends your transfer pricing policy. You’ll need to know where to focus your efforts efficiently. And you’ll need to make sure you meet all requirements from local-country tax authorities, consistently among territories. We can help you tick all these boxes.

We can work with you to:

  • Analyse the potential implications of these new requirements - and identify remedial actions to take, before implementation.
  • Prepare the Master File and ‘core’ Local File, using our GCD concept. This takes the ‘core’ document and uses it in each country as part of its Local File report, wherever you do business.
  • Analyse the output of your country- by- country report, including identifying how you could address any risks.
  • Review consistency of disclosures with the Master File, Local File and local information returns.

Country by country reporting

The Organisation for Economic Co-operation and Development has set a clear deadline for country- by- country reporting (CbCR) data on transfer pricing documentation for fiscal year beginning on or after 1 Jan 2016. It expects this data to be available by end of 2017.

We can help you with your CbCR to:

  • Provide information on your global allocation of profit, taxes paid, and certain indicators of economic activity among the countries in which you operate.
  • Plan your response to CbCR now to avoid significant challenges to businesses.
  • Prepare now by engaging now with your Board and making sure your organisation is in a strong position to to comply with detailed data requests.

Financial services transfer pricing

PwC’s FSTP practice stands at the forefront of identifying and offering expertise on an extensive range of issues and developments within the financial services industry.

We can help you by:

  • Sharing insights and advice to address policy impacts of regulatory developments for FS businesses, gained through our the evolving regulatory landscape driven by organizations like the OECD, European Union, the UN, and other stakeholders.
  • Providing pragmatic advice for sector-specific intercompany issues across the financial services sectors. This might include 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 organisations.

Financial Transactions Transfer Pricing

When it comes to financial transactions transfer pricing, there’s ambiguity due to the absence of direct regulatory guidance. We’re ready to help you overcome the uncertainty. Our global teams include experts with technical and controversy experience, covering the spectrum of intercompany treasury transactions - including loans, guarantees and cash-pooling. We’ve developed technically robust support, ready to implement, across a range of instruments and operations that feel the impacts of finance and related treasury transactions across a multinational organisation.

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TP Controversy and Dispute Resolution

Tax controversies are on the increase globally and companies are facing even more challenges to mitigating tax risk and achieving tax certainty. PwC’s TCDR network helps with the top issues multinational companies and facing today in terms of transfer pricing controversy.

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Value chain analysis

Today, it’s more important than every to identify which activities in your business generate value and how profits get allocated. Increasingly, businesses are turning to Value Chain Analysis (VCA) to do this - particularly in light of the OECD having devoted a significant part of its treatment of the profit-split method to distinguishing the roles of VCA and profit-split. With the BEPS initiatives, particularly OECD‘s unified approach on taxing the digital economy, as well as the economic and business discruption as a result of the Covid-19 pandemic, VCA has become a key analysis to include for assessing the company‘s transfer pricing position.

We can help you to identify which activities in your business generate value and how profits get allocated, by:

  • Explaining the profit profile of your country- by- country reporting
  • Evaluating the resilience of your transfer pricing generally
  • Testing the application of specific methods.

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Operational Transfer Pricing (OTP)

The cross-border intercompany transactions of multinational corporations are in the spotlight like never before. With unprecedented scrutiny from tax authorities, the media and the general public over the way global organizations conduct their financial affairs, driving substantive legislative changes both nationally and internationally, such firms are having to navigate an increasingly complex environment with significant financial and reputational risk.

This has served to place the tax departments of such organizations under increased pressure to have complete confidence in the effectiveness of their wider finance function and take a lead role in ensuring all intercompany transactions are supported by a robust governance framework, are executed through streamlined and efficient processes and have effective controls with a culture of openness and transparency.

Therefore, while transfer pricing compliance relies solely on tax departments, its operations go far beyond tax, to controllership, financial planning and budgeting, treasury, shared services, cultural leadership and other internal functions.

Our PwC Operational Transfer Pricing team can help you develop a holistic approach to govern and revolutionize your Transfer Pricing, from assessing your current processes, governance and control framework, all the way to transforming your intercompany execution using the most effective technologies for your organization.

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Value chain transformation

Our Value Chain Transformation (VCT) team helps businesses align compliant tax strategies with business initiatives and operating models. This is a particularly important task today, in light of OECD BEPS and related initiatives.

We can support you whichever industry you’re in and whichever part of your value chain you’re looking to transform – including supply chain, innovation, marketing and sales, logistics, and global business services.

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Contact us

Horacio Peña

Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817

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