Welcome to our Transfer Pricing and Trade blog series! As global commerce and technology continue to expand, the movement of goods, services and intellectual property across borders becomes increasingly intricate, making transfer pricing a critical focal point for multinational enterprises and tax authorities. Our series will help your company focus on remaining proactive, not reactive, to today's dynamic global market. We will provide in-depth insights and practical guidance on how to navigate the regulatory landscape, achieve operational and tax efficiency and stay ahead an arm's length.
Kristina Novak and John Cianfrone
April 11, 2025
The IRS’s proposed Option 2 under the Simplified and Streamlined Approach (SSA) would allow the agency to impose standardized profit returns on multinationals, even without taxpayer election. While designed to simplify transfer pricing compliance, Option 2 could increase complexity, compliance burdens, and the risk of double taxation—particularly if not widely adopted by other jurisdictions. Without global alignment, companies may face inconsistent application, heightened disputes, and administrative inefficiencies. Multinationals should assess their exposure, prepare for potential IRS enforcement, and engage in policy discussions to protect against growing uncertainty in the international tax landscape.
Chris Murray and Rafi Berkson.
January 14, 2025.
Modernizing intercompany transactions can help multinational organizations succeed through various catalyst events. These external events typically have a direct impact on company financial statements in fast and unexpected ways that are difficult to react to in an agile way with legacy processes. By understanding your data sources, simplifying legacy processes, improving upstream data and leveraging the right technology and team structures, companies can significantly enhance their TP processes.
Kristina Novak, Steven Crawdon and Zachary Noteman.
December 10, 2024.
Transfer pricing (TP) is a relatively new concept in the Middle East. Prompted by changes in the international tax landscape, and domestic economic developments, countries across the Middle East are just beginning to introduce corporate tax regimes, while also aligning their TP regulations with international standards. As governments in the region seek to diversify away from a dependence on oil revenues, they are implementing a series of tax incentives and regulatory changes to increase foreign direct investment and improve the business climate. Meanwhile, for similar reasons, there is also an increased drive to enhance TP enforcement and tax collections. Amid this confluence of events, it is essential for businesses to understand and adapt to the evolving tax and investment landscape in the Middle East.
Kristin Bohl, Brad Slattery, Chase Podsaid and Craig Stronberg.
September 26, 2024.
In today's global business landscape, volatility, uncertainty, complexity and ambiguity—collectively known as VUCA—are more pronounced than ever. The post-Covid era has dismantled traditional geopolitical guardrails, creating a more challenging trade and tax environment, including supply scarcity and a general decrease in trust. Adopting a multidisciplinary approach to these changes from trade, tax and supply chain management perspectives is important for companies to remain competitive, mitigate risks and unforeseen tax costs, and ensure compliance in a rapidly evolving global landscape.
David Ernick and Kristina Novak.
August 23, 2024.
Our latest blog discusses the significance of country-by-country reporting (CbCR) and the challenges faced by multinational enterprises (MNEs) in complying with the CbCR Safe Harbor and Public CbCR requirements. The CbCR Safe Harbor allows MNEs to reduce their obligations under global minimum tax rules, while Public CbCR requires MNEs to disclose their CbCR data to the public. Learn actionable steps that companies can take to ensure compliance with these reporting frameworks, including understanding the implications of CbCR, evaluating the CbCR Safe Harbor, preparing for Public CbCR, protecting sensitive information, and consulting with professionals.
Brian Burt, David Ernick, Kristina Novak, Kartikeya Singh and Andrew Hwang.
February 13, 2024.
The Transitional Country-by-Country report (CbCR) Safe Harbor under Pillar Two offers multinational enterprises (MNEs) a temporary means to reduce or eliminate top-up taxes in certain jurisdictions by meeting one of three criteria. This safe harbor, applicable for fiscal years beginning on or before December 31, 2026, helps MNEs lower compliance obligations and data requirements, provided they use Qualified Financial Statements to prepare their CbCR. Recent guidance emphasizes the importance of accurate data, consistent application, and alignment with transfer pricing policies to qualify for this safe harbor and avoid potential tax disputes.
PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts not only provide you the latest regulatory changes and developments, but also inform you how they can impact your business.
Transfer Pricing Services can help companies develop strategies for business transformation, transparency and reporting, controversy, and compliance related to international tax policy, customs, and global trade.
PwC partners and thought leaders discuss and provide valuable insights on international tax developments around the world. Our podcasts not only provide you the latest regulatory changes and updates, but also explain how these changes can impact your business and offer possible solutions.
Our tax practice provides insights to help you adapt and succeed.
Transfer Pricing & Customs Tax Services Leader, PwC US
