Transfer Pricing

Establishing, documenting, and defending prices for cross border intra-group transactions

Transfer pricing describes all aspects of inter-company pricing arrangements between members of a multinational group, including transfers of tangible goods; services; intellectual property; and loans as well as other financial transactions.

Globalisation has led to cross border intra-group dealings becoming the norm. Taxpayers must comply with the regulatory environment in jurisdictions where they operate, which is time consuming and can be complicated. Tax Authorities frequently exchange information, which increases scrutiny on cross border intra-group dealings and associated business structures, especially where taxable benefits may arise.

When could this be relevant to you

  • You need assistance with supporting your existing transfer pricing policies and meeting documentation requirements for different transaction types?
  • You wish to implement new transfer pricing policies which could be driven by changes in your business and/or supply chain?
  • You are required to defend your transfer prices or need assistance on dispute resolution matters and litigation cases?
  • You are examining the impacts of reforms stemming from the Base Erosion and Profit Shifting project.

What we do

  • Support transfer pricing policies by preparing Masterfiles, Local Files and Country by Country reporting templates, in accordance with regulatory requirements.
  • Develop tax efficient and globally defensible transfer pricing models, in line with commercial business activities and international transfer pricing practices.
  • Advise multinational groups on business restructuring and value chain transformation.
  • Assist businesses with the practical implementation of transfer pricing models and provide Tax Authority dispute resolution services as well as help manage TP litigation cases from prevention and management to resolution.


Draft TP By-Laws published in Saudi Arabia - a landmark moment

In this podcast, PwC Middle East partners Mohamed Serokh, Lav Chadha, and Wael Osman discuss the details of the new Draft Transfer Pricing By-Laws and the impact the new by-laws will have on global multinational groups operating in the Kingdom of Saudi Arabia. See also our webcast covering this landmark development.

For further information, please contact: Mohamed Serokh, Lav Chadha, or Wael Osman

| Duration 27:18

Download episode


PwC Transfer Pricing Perspectives series: Global Inbounds - Multinationals operating in the Middle East. 

Listen here to the latest Webinar from the PwC Middle East Transfer Pricing team talking about the latest regional transfer pricing developments and what they really mean for inbound multinationals, along with the key considerations that require a management and board-room focus

BEPS 2.0 podcast mini-series

In this mini-series, Middle East Transfer Pricing Leader Safae Guennoun and her team take a closer look at BEPS 2.0 and its implications for the region. The show is available in English and in Arabic.

View the series

Value Chain Analysis: Dealing effectively with tax transparency

Whether it is 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 is 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.

For an introduction to VCA for tax, our animation illustrates two different approaches and the relative merits of each.

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Contact us

Zachary Noteman

Zachary Noteman

Partner | Transfer Pricing Tax Leader, PwC Middle East

Tel: +966 54 020 2902

Eric Vroemen

Eric Vroemen

Specialist, Transfer Pricing, PwC Middle East

Andrew  Joshi

Andrew Joshi

Partner Transfer Pricing, PwC Middle East

Mani  Meyer

Mani Meyer

Director Transfer Pricing, PwC Qatar

Tel: +974 4419 2777

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