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Transfer pricing governs the pricing of intra-group transactions between members of a multinational group. Generally, these transactions can be in the form of tangible goods, services, intellectual property or funding.

Transfer pricing continues to be in the spotlight and is an important matter for all multinational groups. In July 2013, the Organisation for Economic Co-operation and Development (OECD) initiated the Base Erosion and Profit Shifting (BEPS) Action Plan. The BEPS Action Plan was finalised in October 2015, and consists of 15 key actions for identifying and curbing aggressive tax planning and practices, and modernizing the international tax system.

In response to this new international environment, KPMG’s transfer pricing practice helps groups develop and implement economically supportable transfer prices, document policies and outcomes and respond to tax authority challenges.

KPMG offers its clients a range of services covering the entire cycle of the decision-making process:

Identifying potential BEPS risks and opportunities resulting from changes to the international tax environment

Defining and implementing appropriate measures to address the potential risks arising from regulatory changes, from a global and local perspective

Complying with the new tax and transfer pricing obligations within the new international tax environment.

KPMG can help groups manage their transfer pricing issues by:

  • Design and developing economically supportable transfer pricing policies
  • Helping manage risk within the current tax environment of detailed transfer pricing regulations, strict documentation requirements, sophisticated audit practices, and significant penalties for non-compliance with an objective perspective which provider consistency when analysing and documenting intra-group transactions
  • Developing and implementing policies, procedures, and systems for setting, monitoring, and documenting intra-group transactions, including assistance with country by country reporting
  • Assistance with transfer pricing disputes, including assistance with advance pricing agreements, competent authority negotiations, arbitration, and litigation support
  • We have a specialist Middle East and South Asia (MESA) transfer pricing team. The team forms part of KPMG’s network of global transfer pricing professionals around the world. This helps us look beyond borders and understand the nuances of different national tax regulations.

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