Multinational enterprises (MNEs) employ transfer pricing to apply arm’s length pricing to their internal cross-border transactions to help ensure they satisfy local tax laws and regulations. To ensure compliance, governments and their revenue authorities have responded by strengthening legislation, demanding stricter documentation of transfer pricing methods, and imposing higher penalties for non-compliance. As a result, transfer pricing – a relatively common internal accounting and taxation practice – has become an increasingly critical element of tax planning for multinational organizations and businesses with global reach.

KPMG can help you develop robust transfer pricing practices and policies that are tax efficient while reducing the risk of challenges from revenue authorities. Our knowledgeable and experienced team of Transfer Pricing Services professionals includes internationally-oriented economists, tax practitioners accountants and lawyers who can assist you in implementing a commercially viable transfer pricing policy, compiling documentation for revenue authority audits, and helping to ensure compliance with local revenue requirements.

Key services

For transfer pricing policies to help support financial performance over the long term, compliance with national rules is just the starting point. At KPMG, we believe that a transfer pricing strategy should be planned out long before transactions occur. Our experienced professionals will work with you to formulate a transfer pricing policy that once implemented, can act as a strategic tool for global tax planning, investment, and supply chain decisions. Our key areas of expertise include:

Planning
An economically supportable transfer pricing strategy is an essential part of forward-looking tax planning. KPMG’s Transfer Pricing Services team leverages experience of professionals with our network of member firms, drawing upon their knowledge and skills in the area of international taxation and transfer pricing. We can help generate transfer pricing strategy that strives to enhance tax efficiencies while aiming to reduce risk exposure.

Implementation
We can provide insightful advice for organizations and businesses moving to implement a revamped transfer pricing strategy. Our tax specialists work along with you to help ensure that new or improved procedures, controls and systems for setting, monitoring, and testing transfer pricing in international business transactions are
implemented.

Controversy
KPMG’s transfer pricing professionals can assist you in resolving the many different types of transfer pricing disputes that frequently arise in the course of doing business on a global scale. We specialize in working with the foreign competent authorities to obtain advance transfer pricing agreements and avoiding double taxation by helping with competent authority negotiation, arbitration, and litigation support.

Compliance and documentation
KPMG’s Transfer Pricing Services team combines an objective point of view with a personalized approach to compliance with transfer pricing regulations and documentation requirements. We can help you maintain compliance and strive to reduce risk exposure within a multitude of different transfer pricing regulations, help you implement practices that help ensure documentation requirements are met, consult on the need for sophisticated audit practices, and advise an effective transfer pricing policy that can help you avoid penalties incurred through non-compliance.

Frequently asked questions

KPMG provides a wide range of transfer pricing services focusing on planning, value chain management, optimization, implementation, controversy, and compliance and documentation. We assist tax leaders in turning their global transfer pricing policies into strategic tools for investment and supply chain decisions, as well as for international tax planning.

KPMG’s Transfer pricing services help develop and implement cost-effective and compliant transfer pricing policies, revamp documentation policies, and effectively respond to operational transfer pricing challenges.

KPMG can show tax leaders the benefits of a technology-enabled, risk-based approach to transfer pricing. Advances in data-driven technology such as robotic process automation (RPA) and enterprise resource planning (ERP) enabled operational transfer pricing methods have made automated data analytics a practical option for most companies. Since good data is the basis for informative benchmarking and reporting, extracting meaningful metrics from transfer pricing processes becomes easier and more effective once an underlying technology-enabled process has been implemented.

An efficient operational transfer pricing policy means that the underlying processes are integrated and coordinated. In leading organizations where technology-enabled solutions are used to help manage transfer pricing processes, the daily transfer pricing business almost takes care of itself.

Many countries have adopted, or are in the process of adopting, changes to their international tax systems in response to the various enacted provisions of the OECD’s Base Erosion and Profit Shifting (BEPS) project. KPMG expects the introduction of new transfer pricing regulation and new data reporting requirements, along with the advent of country-by-country (CbyC) reporting, will pose challenges for MNEs who may see a substantial increase in the number of tax audits as a result.

These disruptive developments have prompted tax leaders at MNEs to reexamine their transfer pricing strategies as we move into the post-BEPS world. KPMG’s Transfer Pricing Service professionals stand ready to support tax leaders as they review, remediate, or even revamp their business structure, tax planning and transfer pricing policies to help minimize risk exposure and avoid base erosion and profit shifting (BEPS) related controversy.

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