No matter how well a transfer pricing system is planned, it is the implementation that determines its success. Both with regard to the realisation of the desired tax effects and the resilience in tax audits at home and abroad.
Successful implementation begins with anchoring the transfer pricing system in the company organisation and the underlying processes. In this context, it is important to continuously monitor the implementation in conformity with the contract by means of process and key figure reporting, among other things, as well as the possibility of short-term, but system-compliant/congruent interventions in the form of price adjustments. Depending on the risk assessment, it may be advisable to pro-actively hedge the risk, for example by means of a pre-agreement procedure.
We support you in putting your transfer pricing system into practice. What we can do for you:
The design and implementation of process and transfer pricing guidelines,
the support in the contractual implementation of transfer pricing systems,
the anchoring of transfer pricing methods in internal and external accounting (e.g. KPI selection, reconciliation of transfer pricing with cost centre/account structure),
the (IT-supported) control and monitoring of transfer prices (operational transfer pricing, data & analytics) as well as
the planning, preparation and implementation of bilateral and multilateral advance pricing agreements (APAs).
Partner, National Leader of the Global Transfer Pricing Service Line, Tax
KPMG AG Wirtschaftsprüfungsgesellschaft