Transfer pricing (TP) services

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. Tax departments are focused on substance, having the right facts and documentation to support tax positions, and managing their global tax footprint.

We can help you:

• Work on a flexible, future-focused transfer pricing strategy
• Assist with preparations for the significant changes expected from the OECD’s Two-Pillar project and foreign tax reform

Companies continue to adapt to changing US and global tax policies, like Pillar Two, BEAT, GILTI, FDII and 163(j). Customs considerations and supply chain considerations put additional pressure on getting transfer pricing policies correct and consistent, with a heavier price for retroactive measures. Companies also have to constantly reinvent themselves to adapt to unpredictable economic and geopolitical circumstances. This requires just as much agility from a tax operating model perspective. Our Value Chain Transformation services can help companies integrate tax planning with operating models to develop efficient and innovative strategies around trade, supply chain and digitalization.

Learn more about VCT

Intercompany transactions are under the microscope. With global and US tax reform reshaping expectations, how you structure and manage transfer pricing has never mattered more. A strong operational transfer pricing strategy bridges the gap between policy and execution — bringing tax, controllership, treasury and shared services into alignment. We can help you turn tax complexity into operational clarity — leveraging your existing tech investments to build governance that scales and transforms how intercompany transactions work.

Transparency and sustainability expectations are rising — and so is the pressure to explain how and where you create value. With public country-by-country reporting gaining traction, companies are facing new scrutiny over profit allocation and transfer pricing resilience. Now more than ever, it’s crucial to understand which activities drive value, how profits are distributed and whether your approach stands up to scrutiny – backed by data and grounded in market realities.

We don’t just step in during disputes — we’re with you from the start. Our transfer pricing controversy team is embedded in day-to-day global structuring to help you anticipate risk and prepare for scrutiny. With deep technical experience — and a team that includes former Treasury and IRS officials — we bring insights and relationships that can accelerate resolution and drive better outcomes.