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:
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