Transfer pricing (TP) services

Tax authorities worldwide are imposing new, stricter documentation requirements on transfer pricing arrangements. Contracts are no longer definitive but a starting point to determine whether the substance of the business aligns with the delineation of functions. Effective transfer pricing documentation will require a shift from core compliance requirements to delivering a compelling narrative of the functions and risks and how control is allocated throughout the organization. In light of recent tax reform measures, there is now a need for multiple sets of documentations sourced from multiple sources of financial data. With the drive for transparency here to stay, a need for consistency across all documentation and corresponding course of conduct is in the spotlight.

Our global network of transfer pricing professionals can help you:

• Reassess your current transfer pricing policies and make them fit for the future
• Assess gaps in your current transfer pricing documentation
• Create a reporting strategy that can effectively integrate data from different executive departments and operational systems
• Systematically address deadlines and requirements related to all aspects of transfer pricing and related documentation - from customs reporting to transfer pricing information returns to country-by-country reporting and the requirements imposed by Amount B and the Pillar Two GloBE information return
• Streamline 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. 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 transfer pricing strategy fit for the future.
• 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.

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In the age of global and U.S. Tax reform, companies have never faced so much scrutiny for their intercompany transactions. The structure and process put in place for companies to manage its tax obligations is therefore critical. With a solid operational transfer pricing strategy, companies can bridge the gap between transfer pricing policies and day-to-day execution.

Operational transfer pricing 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.

Transparency and sustainability demands on companies have escalated, especially with the recent developments surrounding public country-by-country reporting. 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, supported by empirical data and market realities.

Disputes have been on the rise for years, and all markers point toward this trend increasing. Our Tax controversy and dispute resolution services can help companies proactively manage disputes and audits. Our controversy practice benefits companies by having involvement in their day-to-day global structuring needs. The transfer pricing controversy practice also includes an impressive roster of ex-Treasury and IRS officials that can provide critical insights and build on established relationships to resolve issues efficiently.

Explore our tax controversy and dispute resolution services