Transfer Pricing Services

Develop a clear roadmap for process improvements by gaining a deep understanding of the strengths and weaknesses of your transfer pricing system. Our Healthcheck conducts a thorough analysis of data and information on intra-group transactions, examines the functions and risks of involved entities, reviews transfer pricing documentation reports and compliance documents such as CbCR and TP Returns, and evaluates processes related to transfer pricing.

This comprehensive assessment provides valuable insights into your system’s strengths and weaknesses. A prioritized action plan enables you to implement the most impactful system and process enhancements.

Adjust and enhance your transfer pricing system to keep pace with business changes or evolving regulations. The planning phase ensures that profit attribution aligns with the value contribution of individual entities. This need for planning may arise from business model transformations, such as centralizing certain activities, regulatory changes, M&A activities, or the expansion of the group with new entities.

Transfer pricing should effectively support operational business while considering key factors such as global tax burden, regulatory compliance, and the day-to-day management of transfer prices.

We bring your transfer pricing policies to life by integrating them into your systems and leveraging the right technology. Effective implementation requires embedding transfer pricing policies into ERP systems and ensuring daily management of prices.

From a transfer pricing perspective, the focus is on achieving targeted financial outcomes for individual group entities. This process involves reviewing and refining existing workflows, establishing robust controls, and selecting the most suitable technology to automate key aspects—or even the entirety—of transfer pricing operations.
 

> Read more about Operational Transfer Pricing

Strengthen your compliance with a global documentation framework that ensures modular, easy-to-update reports. In an era of increasing scrutiny from tax authorities, properly documenting the arm’s length nature of transfer prices and meeting compliance requirements across all relevant jurisdictions is more critical than ever to safeguard your reputation. We design and implement a global documentation process that enables consistent and reliable reporting of your transfer pricing system wherever required.

Our modular approach enhances efficiency, generates synergies, and improves consistency using advanced data and analytics techniques. Whether you require a fully outsourced documentation solution or support with specific aspects of your compliance process, KPMG is here to guide and assist you every step of the way.

When facing a tax audit, we provide expert support in negotiations with tax authorities, mutual agreement procedures, and risk reduction strategies through tax rulings or Advance Pricing Agreements (APAs). With tax audit intensity rising globally—often with a focus on transfer pricing—preparing through a risk assessment can be invaluable.

During an audit, we assist in responding to authority requests, engaging in discussions and negotiations, and handling disputes, including court cases related to income adjustments. To proactively mitigate risks, we also support you in obtaining tax rulings or APAs, ensuring greater certainty and compliance in your transfer pricing strategy.