Global transfer Pricing services

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:

• EU public country-by-country reporting tracker
• Australia public country-by-country reportingOpens in a new window
• 10 step plan to publish country-by-country reporting (PDF)Opens in a new window

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.

We can help you by:

• Sharing insights and advice to address policy impacts of regulatory developments for financial services (FS) businesses, gained through our monitoring of the evolving regulatory landscape driven by organisations like the OECD, European Union, the UN, central banks and other stakeholders. 
• Providing pragmatic advice for sector-specific intercompany issues across FS sectors. Our guidance spans transfer pricing issues associated with cross-border real estate transactions; management company structures across traditional, alternative, or private equity Asset Management groups; proportional or treaty-based risk ceding transactions, and risk support or other services transactions for Insurance groups; and trading services, booking models, services, and other intercompany issues for Banking and Capital Market organisations. 
• Bringing sector expertise in the key service offerings provided by PwC including TP controversy and dispute resolution, GCD, and public country-by-country reporting. We link this expertise to the fast-changing environment facing FS clients today; helping clients navigate evolving value-chains and the rise of technology, sustainability and increased transparency. 

View an engaging discussion with our PwC specialists on FSTP key trends in asset management.

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: 

• Planning and consulting
• Pricing and policy setting
• Derivation of arm’s-length interest rates
• Debt-capacity and serviceability analysis
• Transaction support around key funding events 
• Locally compliant documentation
• Advance rulings
• Tax audit and dispute resolution
• Automation and technology

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. 

We can work with you to: 

• Develop controls, appropriate documentation and design processes to help you prevent controversy. We believe day-one readiness is your most effective defence against the spectrum of risk, mitigating its potential impact across your business, including reputational risk.
• Share insights to help you strategize for audits, leveraging decades of former Tax Authority and Competent Authority experience. When disputes are unavoidable, we believe in navigating those matters to faster resolution and better results.
• Support and manage double taxation via Mutual Agreement Procedures and litigation.
• Achieve greater certainty via Advanced Pricing Agreements.
• Consider the use of technology in your controversy function to help create bandwidth to think strategically and ensure consistency in response.

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.

Learn more

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. 

We can help you by: 

• Providing insight on how other companies are handling the changing environment as well as strategies being implemented. 
• Listening to your business objectives and bringing an outside-in perspective. 
• Evaluating your value chain management process and finding a path to improvement. 
• Exploring value chain improvement options and co-developing the appropriate solution for your company. 
• Presenting tailored options that are aligned to your specific footprint and fact pattern