Transfer Pricing

Transfer pricing is a critical area of focus for multinational groups operating across borders. With tax authorities worldwide intensifying their scrutiny of related-party transactions, having a coherent and defensible transfer pricing framework is essential.

Transfer pricing is now formally regulated in Malta. Entities engaged in cross-border arrangements with associated enterprises are now subject to transfer pricing documentation and compliance obligations.

At PwC Malta, we combine local knowledge with the strength of our global network of transfer pricing specialists. Whether you are navigating the Maltese TP Rules for the first time or managing a complex, multi-jurisdictional framework, we work alongside you to manage risk, ensure compliance, and identify opportunities.

Our services include:

• Transfer pricing compliance and documentation: preparation of Master Files and Local Files in line with the OECD Guidelines and the Maltese TP Rules.

• Transfer pricing policy design and review: assessment and structuring of transfer pricing policies to ensure alignment with the arm's length principle.

• Benchmarking studies: economic analyses to support the pricing of intercompany transactions.

• Advance Pricing Agreements (APAs) and rulings: assistance with applications for transfer pricing rulings and APAs.

• Transfer pricing risk management and dispute resolution: support during tax audits and assistance with mutual agreement procedures.

• Country-by-Country Reporting (CbCR): guidance on CbCR obligations and filing requirements.

• Public CbCR: assistance with public Country-by-Country Reporting obligations under the EU directive, including disclosure requirements and compliance.

• Training and awareness: tailored transfer pricing training for your finance, tax, and management teams.