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Transfer pricing occurs as multinationals look to establish their intercompany pricing agreements across the world. Between escalating documentation and compliance requirements, strict penalties, rampant audit activity and a focus on corporations ‘paying their fair share,’ never before have companies faced so much scrutiny over their transfer pricing policies.
With more than 3,100 specialists deployed in over 90 countries—we are well positioned to advise you on developing compliant, tax-efficient structures that help advance your business goals.
Tax authorities worldwide are imposing new, stricter documentation on transfer pricing arrangements. Success factors for future transfer pricing documentation will require a shift from compliance to strategic risk management. With the drive for transparency here to stay, a need for consistency across all documentation is in the spotlight.
Our global network of transfer pricing professionals can help you:
Assessing gaps in your current transfer pricing documentation
Creating a transfer pricing documentation strategy fit for the future
All aspects of transfer pricing documentation - from transfer pricing information returns to the anticipated country-by-country reporting,
Streamlining the process to develop robust, coordinated transfer pricing documentation through our Global Coordinated Documentation™ framework.
Multinationals face heightened interest in their tax and transfer pricing positions. No longer just of interest to tax authorities, corporate tax positions have moved up the government and public agenda. The arm’s length standard, the historic backbone of price-setting for intercompany transactions, is under attack. An increase in profit splits is expected. Tax departments are focused on substance, having the right facts to support tax positions, and managing their permanent establishments.
We can help you with:
Working on a transfer pricing strategy fit for the future.
Helping prepare for the significant changes expected from the OECD activity on base erosion and profit shifting.
Companies continue to adapt to changing US and global tax policies like BEAT, GILTI, FDII and 163(j). Our Value Chain Transformation services can help companies integrate tax planning with operating models to develop efficient and innovative strategies around supply chain.
Multinational corporations are under scrutiny for intercompany transactions. In the age of BEPS and U.S. Tax reform companies are focused on driving greater standardization/efficiency, eliminating duplication and driving supply chain performance.
While transfer pricing compliance relies solely on tax departments, intercompany execution goes far beyond tax to controllership, treasury, shared services and other internal functions. PwC can help you leverage corporate technology investments to create a holistic approach to governance and revolutionize the process for intercompany transactions.
Whether it is explaining the profit profile of your country by country reporting, evaluating the resilience of your transfer pricing (TP) 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.
Recent events have resulted in a substantial increase in the number of tax audits, assessments and disputes with revenue authorities. Our Tax controversy and dispute resolution services can help Multi National Corporations from prevention to audit management through post audit settlement.