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Welcome to our Transfer Pricing and Trade blog series! As global commerce and technology continue to expand, the movement of goods, services and intellectual property across borders becomes increasingly intricate, making transfer pricing a critical focal point for multinational enterprises and tax authorities. Our series will help your company focus on remaining proactive, not reactive, to today's dynamic global market. We will provide in-depth insights and practical guidance on how to navigate the regulatory landscape, achieve operational and tax efficiency and stay ahead an arm's length.
From scrutiny to strategy: Building a resilient intercompany services framework
Kristina Novak, Marco Fiaccadori and John Cianfrone
November 17, 2025
Intercompany services transactions continue to present important and evolving challenges for taxpayers. These transactions often involve a multitude of transfer pricing considerations, and their treatment for transfer pricing purposes has the potential to impact non-transfer pricing tax items. Around the world, tax authorities are increasingly reviewing and scrutinizing services transactions. As a result, intercompany services arrangements remain an important component of most taxpayers’ transfer pricing profile.
Navigating the Shift: AI in transfer pricing - Greater accuracy and enhanced insights
Erin March, Rafi Berkson
October 20, 2025
Every organization must now decide how to design around the AI skills and capabilities that will define the tax function of the future. In transfer pricing, that decision is urgent. With global rules in flux and disputes on the rise, transfer pricing specialists are moving from reactive defense to proactive control. AI-powered workflows and disciplined data not only unlock robust compliance but also help you reduce risk and surface insights that fuel business strategy to facilitate better decision-making.
Staying ahead of the shifting UK transfer pricing landscape
James Andrews, Sonia Watson, Sara Harris and Kristina Novak
September 15, 2025
HMRC is tightening UK transfer pricing oversight with stricter documentation rules, expanded audits and nearly £2 billion recovered in 2023–24. New requirements from April 2023 mandate Master and Local Files, while proposed reforms aim to simplify rules, align with OECD standards and broaden scope through changes to exemptions, permanent establishment rules and a new Unassessed Transfer Pricing Profits regime. With compliance deadlines approaching in 2025, businesses must strengthen documentation, governance and risk management to meet rising expectations.
What the IRS’s proposed Option 2 under Amount B means for multinationals
Kristina Novak and John Cianfrone
April 11, 2025
The IRS’s proposed Option 2 under the Simplified and Streamlined Approach (SSA) would allow the agency to impose standardized profit returns on multinationals, even without taxpayer election. While designed to simplify transfer pricing compliance, Option 2 could increase complexity, compliance burdens, and the risk of double taxation—particularly if not widely adopted by other jurisdictions. Without global alignment, companies may face inconsistent application, heightened disputes, and administrative inefficiencies. Multinationals should assess their exposure, prepare for potential IRS enforcement, and engage in policy discussions to protect against growing uncertainty in the international tax landscape.
How a modernized approach to intercompany transactions can help businesses today
Chris Murray and Rafi Berkson.
January 14, 2025.
Modernizing intercompany transactions can help multinational organizations succeed through various catalyst events. These external events typically have a direct impact on company financial statements in fast and unexpected ways that are difficult to react to in an agile way with legacy processes. By understanding your data sources, simplifying legacy processes, improving upstream data and leveraging the right technology and team structures, companies can significantly enhance their TP processes.
Transfer pricing in the Middle East: What multinationals need to know about
Kristina Novak, Steven Crawdon and Zachary Noteman.
December 10, 2024.
Transfer pricing (TP) is a relatively new concept in the Middle East. Prompted by changes in the international tax landscape, and domestic economic developments, countries across the Middle East are just beginning to introduce corporate tax regimes, while also aligning their TP regulations with international standards. As governments in the region seek to diversify away from a dependence on oil revenues, they are implementing a series of tax incentives and regulatory changes to increase foreign direct investment and improve the business climate. Meanwhile, for similar reasons, there is also an increased drive to enhance TP enforcement and tax collections. Amid this confluence of events, it is essential for businesses to understand and adapt to the evolving tax and investment landscape in the Middle East.
Smoother sailing for supply chains through the lens of trade and tax
Kristin Bohl, Brad Slattery, Chase Podsaid and Craig Stronberg.
September 26, 2024.
In today's global business landscape, volatility, uncertainty, complexity and ambiguity—collectively known as VUCA—are more pronounced than ever. The post-Covid era has dismantled traditional geopolitical guardrails, creating a more challenging trade and tax environment, including supply scarcity and a general decrease in trust. Adopting a multidisciplinary approach to these changes from trade, tax and supply chain management perspectives is important for companies to remain competitive, mitigate risks and unforeseen tax costs, and ensure compliance in a rapidly evolving global landscape.
Navigating change: Steer your company through the effects of country-by-country reporting
David Ernick and Kristina Novak.
August 23, 2024.
Our latest blog discusses the significance of country-by-country reporting (CbCR) and the challenges faced by multinational enterprises (MNEs) in complying with the CbCR Safe Harbor and Public CbCR requirements. The CbCR Safe Harbor allows MNEs to reduce their obligations under global minimum tax rules, while Public CbCR requires MNEs to disclose their CbCR data to the public. Learn actionable steps that companies can take to ensure compliance with these reporting frameworks, including understanding the implications of CbCR, evaluating the CbCR Safe Harbor, preparing for Public CbCR, protecting sensitive information, and consulting with professionals.
Transfer Pricing and the Pillar Two Transitional CbCR Safe Harbor: What do you need to know to transform?
Brian Burt, David Ernick, Kristina Novak, Kartikeya Singh and Andrew Hwang.
February 13, 2024.
The Transitional Country-by-Country report (CbCR) Safe Harbor under Pillar Two offers multinational enterprises (MNEs) a temporary means to reduce or eliminate top-up taxes in certain jurisdictions by meeting one of three criteria. This safe harbor, applicable for fiscal years beginning on or before December 31, 2026, helps MNEs lower compliance obligations and data requirements, provided they use Qualified Financial Statements to prepare their CbCR. Recent guidance emphasizes the importance of accurate data, consistent application, and alignment with transfer pricing policies to qualify for this safe harbor and avoid potential tax disputes.
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