Transfer pricing: Global Coordinated Documentation

 It's high time - a focus on the Global TP landscape

  1. The NEED to have TP on top of mind and for global TP documentation increased with the expansion of TP documentation and reporting requirements by the OECD, back in September 2014.
  2. The OPPORTUNITY for strategic tax risk management should be taken each time you prepare your global TP documentation. The successful documentation exercise is more than pure compliance to mitigate tax exposures.
  3. The BURDENSOME PROCESS of documentation currently asks for multiple tiers of documentation (Master File, Local File, Country-by-Country Report, and local information returns), which you should harmonise.
  4. The TECHNOLOGY CHALLENGE arises when pressure is put on a group’s systems to deliver the source data required on a timely basis and pressure to co-ordinate the preparation of all the relevant global and local TP documentation.


PwC’s Global Coordinated Documentation™ (GCD) - global coordination, readiness everywhere

A consistent and efficient framework to deliver the required level of TP documentation

  1. TIMELY completion of the global TP documentation, to meet each deadline set in the jurisdictions you operate
  2. PROACTIVE identification and mitigation of significant TP risk by analysing related party transactions from all angles
  3. FLEXIBLE process of documentation that complements and /or supplements your internal tax resources and keeps everyone in the loop based on well-defined roles and responsibilities
  4. ENHANCED technology used in the process, to help you create consistent deliverables through a coherent building process

In summary, PwC’s GCD framework will provide you with the opportunity to assess any gaps, allow you to monitor and continually reassess your worldwide TP, and stay one step ahead of tax authorities’ TP documentation requirements. 

Informal meeting

PwC’s Global Coordinated Documentation Reporter™ (GCDR) technology - the enabler of successful global TP documentation



  • GOAL ACHIEVED: Assess the impact of the OECD’s Chapter V changes and analyse your global footprint by jurisdiction - use technology enabled visualisations in the process
  • GOAL ACHIEVED: Prepare the Master File and ‘core’ Local File centrally utilising the GCD framework and PwC's proprietary GCDR software. The ‘core’ document will then be used by each jurisdiction as part of its local TP documentation, and with the support of our global team, you will prepare a Local File which meets the specific local requirements in each jurisdiction where you do business; and – use a coherent technology enabled completion and review process of all deliverables
  • GOAL ACHIEVED: Review the consistency of disclosures made in the Master File, the Local Files and local information returns – pre-set usage of technology to minimise mismatches of information

Contact us

Matias  Pedevilla

Matias Pedevilla

Global Coordinated Documentation Leader

Tel: +1 (305) 347 3544

Horacio Peña

Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817

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