Tax authorities worldwide are imposing new, stricter documentation requirements on transfer pricing arrangements. Contracts are no longer definitive but a starting point to determine whether the substance of the business aligns with the delineation of functions. Effective transfer pricing documentation will require a shift from core compliance requirements to delivering a compelling narrative of the functions and risks and how control is allocated throughout the organization. In light of recent tax reform measures, there is now a need for multiple sets of documentations sourced from multiple sources of financial data. With the drive for transparency here to stay, a need for consistency across all documentation and corresponding course of conduct is in the spotlight.
Our global network of transfer pricing professionals can help you:
- Reassess your current transfer pricing policies and make them fit for the future
- Assess gaps in your current transfer pricing documentation
- Create a reporting strategy that can effectively integrate data from different executive departments and operational systems
- Systematically address deadlines and requirements related to all aspects of transfer pricing and related documentation - from customs reporting to transfer pricing information returns to country-by-country reporting and the requirements imposed by Amount B and the Pillar Two GloBE information return
- Streamline the process to develop robust, coordinated transfer pricing documentation through our Global Coordinated Documentation™ framework.