Transfer pricing is a key component where business and tax intersect for multinational companies. Intercompany pricing remains a challenge in the ever-evolving legal and geopolitical landscape. Between local country and global tax reforms, escalating inconsistent and conflicting documentation and compliance requirements, strict penalties, and high-stakes audit activity, companies face elevated scrutiny over their transfer pricing policies.
PwC has over 5,500 specialists in over 150 countries, ready to support you with AI aided solutions around transfer pricing documentation, planning, and controversy & dispute resolution. Together, we can advise and develop compliant, industry-leading frameworks that drive your business objectives. Whether you are seeking guidance for effective corporate governance and internal controls for transfer pricing matters, defensible documentation on the allocation of system profit across the value chain and country borders, support through controversy, or analytics and automation for workflow management, our transfer pricing professionals are well positioned to advise you.
Today, your business faces demand for increased transparency and greater disclosure requirements. That means you’ll need an efficient, consistent framework for producing the documentation that defends your transfer pricing policy. You’ll need to know where to focus your efforts efficiently. And you’ll need to make sure you meet all requirements from local-country tax authorities, consistently among territories. PwC can help you tick all these boxes.
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The integration of tax within sustainability increases as tax transparency becomes a significant part of companies' sustainability efforts. Companies' tax contributions can positively impact local communities and environmental initiatives in territories where they operate, but this story is often not told or well understood.
With reporting requirements pending, the disclosure of pCbCR will be uncharted waters for most companies and is likely to represent the first time potentially sensitive country-level data on tax and profits will be made publicly available. The focus of pCbCR is on corporate income taxes, however new regulation gives businesses an opportunity and a foundation from which to tell their holistic tax story and help build trust with stakeholders.
Both the EU and Australia have introduced pCbCR reporting obligations. Find out more about pCbCR and how we can help:
PwC’s financial services transfer pricing (FSTP) practice stands at the forefront of identifying and offering expertise on an extensive range of issues and developments within the financial services industry.
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View an engaging discussion with our PwC specialists on FSTP key trends in asset management.
Our global and country-specific financial transactions transfer pricing (FTTP) network provides you with a depth of experience to deliver tailored, sustainable solutions in a dynamically changing global FTTP environment.
Financial transactions are wide ranging, from straightforward loans to pricing of complex derivative products, cash pooling, factoring, as well as broader treasury operations (netting, hedging, foreign exchange management) and often can be material transactions within multinational groups. These transactions are central to funding across the multinational group and service liquidity provision, long term funding, and other operational and tax needs. Following revisions to the OECD Guidelines, greater scrutiny is placed on the economic substance of financial transactions, options realistically available to the counterparties, and ability/capacity to bear risk within entities of a multinational group. There has also been a shift in the way in which tax authorities have sought to analyse and challenge intercompany loans, guarantees, cash pooling and other financial transactions from a transfer pricing perspective.
We can help you by providing support around the entire life cycle of intercompany treasury activity, including:
Today, your business faces an ever-increasing risk of burdensome and complex TP controversy. In a world of increasing transparency, greater disclosure requirements, and an increasing trend of cross border information exchange, the risk of controversy and the need to effectively manage disputes has never been greater. In this environment, you need an end-to-end TP controversy partner that will support you in taking a proactive approach to preventing, managing, and resolving TP disputes, keeping you ahead of controversy and more in control of the challenges it can create for your business.
At PwC, our TP controversy team is uniquely qualified to help you navigate disputes to faster resolution and better results. Offering a full range of controversy services along with collaborative technologies, we cover areas ranging from early risk identification and audit readiness to global dispute resolution. We are dedicated to keeping your company resolution-ready, resolving your TP controversies and delivering outcomes you can trust.
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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.
The world of transfer pricing is rapidly evolving. There is an ever-increasing wave of legislative and regulatory change, tax authorities are more sophisticated when it comes to data and systems and asking MNCs to “prove” the correct execution of their position in accordance with the transfer pricing policy, and in-house tax/transfer pricing teams are being asked to do “more with less” and get up the digital curve while being more closely aligned with the finance function. Amongst this change, there is a once in a generation shift with the introduction of ERP and Cloud based solutions which can more effectively digest, transform, calculate, and report data from core and non-core systems.
PwC’s operational transfer pricing (OTP) team specializes to help clients harness the opportunities around more efficient and effective transfer pricing execution, ranging from data extraction and transformation, designing segmentation/allocation/calculation frameworks, to reviewing and modelling outcomes and production of outputs. Our approach is technology agnostic, and we work with clients to improve data, use technology as an enabler around an operating model that is focused on a target people, process, and governance framework.
Solutions can range from being incorporated in a workstream of a larger organization-wide ERP migration or Finance Transformation initiative, to a transfer pricing focused project leveraging technology and approaches already existing within the organization. Whether a short sprint or large scale, multi-year integration, we tailor solutions to your organization’s goals.
In today’s global business landscape, companies are continuously faced with increasing volatility and uncertainty. Coupled with a more challenging tax and trade environment, amplified by the impacts of Pillar Two as well as other trade-related geopolitical impacts, companies are having to navigate this uncertainty and headwinds on a real-time basis and with a forward-looking lens. From an end consumer perspective, expectations around service delivery, automation and AI also continue to escalate, putting pressure on companies to innovate at pace.
Our value chain transformation services can help companies integrate aligned legal, governance and tax structures with business operating models to develop efficient and innovative strategies around trade, supply chain, and digitalization in a way that will create long-term enterprise value and address short term risk and costs.
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