Transfer pricing services

Multinational companies are operating in an increasingly regulated environment. International standards supported by OECD (Organisation for Economic Co-operation and Development) 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 related risks. Even with the right record-keeping and support, tax audits over transfer pricing can still occur. To mitigate risks in this environment, taxpayers need to analyse their transfer pricing arrangements and maintain appropriate documentation.

PwC Tax Japan’s Transfer Pricing Team can assist you with your transfer pricing needs, including helping you prepare your Local File and assisting you with advance pricing agreements. Our team members have extensive training and experience in this area, from helping clients navigate the new CbC reporting requirements to crafting reliable and accurate transfer pricing studies. Our global network of PwC member firms is also ready to assist you with your localized needs.

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Our Team

Daisuke Miyajima

Partner, PwC United Kingdom, PwC Japan


Goro Mizushima

Partner, PwC Tax Japan