Transfer Pricing Services

We drive intra-group value

The tax landscape is driven by growing government scrutiny and rising regulation. At the same time, tax audits are on the rise. In a digitalized, automated and connected world, transfer pricing requires automated processes. Companies need to respond to this increasing pressure.

Transfer Pricing inherently is a multinational topic - seamlessly working across borders to solve issues is therefore paramount to successful projects. Globally, KPMG Global Transfer Pricing Services has access to more than 2'870 transfer pricing experts in all relevant countries of the world. We work together with specialists in all tax areas, and are integrated in the strong global KPMG network of Audit, Tax and Advisory experts.

Gerhard Foth

Partner, Global Transfer Pricing Services

KPMG Switzerland

Why KPMG Transfer Pricing Services?

Transfer pricing has become much more complex in view of the ongoing digitalization, new business models and increasing tax transparency. Multinational groups need a partner that provides guidance through this complexity.

We help to identify risks and opportunities related to intra-group transactions. We plan sustainable and pragmatic transfer pricing systems and help with the operational implementation. Finally, we also support your transfer pricing compliance and manage as well as mitigate risks arising in tax audits, thus driving value and maintaining your reputation.

We understand the needs of our clients and call this continuous and sustainable improvement process "KPMG's TP Lifecycle".

Our clients will benefit from a transfer pricing system that not only lowers costs but also increases the efficiency in the daily management of transfer prices through meaningful insights into data and analyses. Our proven and well-established approach enables compliance with the help of automated processes. This supports your governance, risk management and compliance.

Navigating success: our proven approach

  1. Healthcheck

    Set out a roadmap to improve processes in view of a comprehensive understanding of the strengths and weaknesses of your transfer pricing system.

  2. Planning

    Change and optimize your transfer pricing system to accompany changes in your business or revised regulation.

  3. Operational Transfer Pricing

    We implement your transfer pricing system based on your transfer pricing policies by using appropriate technology.

  4. Enhanced Compliance

    Improve your compliance with a global documentation process that creates modular and easy-to-update documentation reports.

  5. Dispute Resolution

    Have a tax audit coming up? We will support in negotiations with tax authorities and in mutual agreement procedures, lower your risks with the help of tax rulings or advance pricing agreements.

KPMG's TP Lifecycle KPMG's TP Lifecycle


Clients benefit from Stage 1 of KPMG’s TP Lifecycle with a thorough analysis of the status quo.

Our Health Check analyzes data and information on intra-group transactions, functions and risks of entities involved in such transactions, transfer pricing documentation reports and other compliance documents such as CbCR or TP Returns, as well as processes in the area of transfer pricing.

These analyses offer a comprehensive understanding of the strengths and weaknesses of your transfer pricing system. A prioritized action list empowers you to make the most valuable system and process improvements.

Your benefits

  • Transparency on risks, such as lack of compliance
  • Transparency on opportunities, such as simplification potential in the operational handling of transfer prices
  • Targeted prioritization of potential actions
  • Optimized use of resources
  • Improved processes

Our expertise

  • Analysis of transfer pricing systems
  • Evaluation of documentation quality
  • Evaluation of transfer pricing processes


Clients benefit from Stage 2 of KPMG’s TP Lifecycle with the setup of a sustainable transfer pricing system.

The planning stage allows you to align the profit attribution resulting from your transfer pricing system with the value contribution of individual entities. The need for planning may be triggered by changes in the business model (e.g. centralization of certain activities), regulatory developments, activities in the M&A area, or the expansion of the group with new entities.

Transfer prices should best support the operational business. At the same time, aspects such as global tax burden, regulatory requirements, compliance, as well as the operational day-to-day management of the transfer prices need to be taken into account.

Your benefits

  • Optimized global tax burden 
  • Protection of reputation
  • Sustainable transfer pricing policies
  • Lower risk costs
  • Lower compliance costs

Our expertise

  • Analysis of your business model from a TP perspective
  • Value Chain Analyses
  • Development of sustainable transfer pricing systems
  • Preparation of benchmark analyses

Operational Transfer Pricing

Clients benefit from Stage 3 of KPMG’s TP Lifecycle with the operational implementation and day-to-day management of their transfer pricing system.

Transfer Pricing policies need to be implemented in ERP systems and prices need to be managed on a day-to-day basis. From a transfer pricing perspective, particular emphasis is put on achieving certain target results in individual group companies.

This includes reviewing and defining processes and controls as well as selecting and implementing appropriate technology to automate parts or all of these processes.

Your benefits

  • Effective transfer pricing system implementation
  • Less effort for administration and controls  of target margins
  • Leading technology that supports your processes  in setting and managing transfer prices
  • Professional management of transfer pricing adjustments

Our expertise

  • Evaluate, develop and implement processes needed in the daily management of transfer prices
  • Select and implement appropriate software to automate price adjustments

Enhanced Compliance

Clients benefit from Stage 4 of KPMG's TP Lifecycle with a global documentation process that creates modular and easy to update documentation reports as compliance requirements and tax authority scrutiny are on the rise globally.

To protect reputation and be prepared for scrutiny and challenges from tax authorities, it is more important than ever to properly document the arm's length character of transfer prices and fulfill other transfer pricing compliance requirements consistently in all relevant jurisdictions.

We manage your compliance by designing and implementing a global documentation process that enables you to consistently document your transfer pricing system wherever required. The modular documentation reports ensure an efficient documentation preparation, generating synergies and enhancing consistency through data & analytics techniques. Whether you need a full end-to-end outsourced documentation service or simply need KPMG for selected parts of your documentation and compliance process - we are there to guide and support you.

Your benefits

  • Thorough transfer pricing documentation
  • Global process for improved quality and consistency
  • Higher data accuracy and more data insights
  • Lower risk costs
  • Lower compliance costs

Our expertise

  • Preparation of group-wide global transfer pricing documentation
  • Development of a global update process of your documentation
  • Establishing data models for transfer pricing purposes 
  • Support in the compliance with other rules and regulation, such as transfer pricing returns, etc.
  • Support in the compliance of obligations for the country-by-country reporting

Dispute Resolution

Clients benefit from Stage 5 of KPMG’s TP Lifecycle with ongoing support and assistance during tax audits or in other negotiations with tax authorities.

Tax audit intensity is increasing worldwide – often with a focus on transfer pricing. A risk assessment in preparation for a tax audit can help to prepare. During an audit, we can assist with answering requests from authorities or discussing and negotiating with tax authorities. We can also help if you need assistance with mutual agreement procedures or if it comes to court cases with respect to income adjustments.

Interested in mitigating such risks? We also support you in case you would like to obtain a tax ruling or an Advance Pricing Agreement to eliminate transfer pricing risks.

Your benefits

  • Lower or no double taxation
  • Mitigated tax risk with Mutual Agreement Procedures or Advance Pricing Agreements

Our expertise

  • Support in tax audits related to transfer pricing
  • Assistance with Mutual Agreement Procedures and Advance Pricing Agreements
  • Global management of tax audits
  • Preparation of tax rulings regarding transfer pricing

Partnering for success: submit your interests & open questions

We look forward to your requests and will be happy to answer open questions you may have. 

Meet our experts

Gerhard Foth

Partner, Global Transfer Pricing Services

KPMG Switzerland

Mischa Sollberger

Partner, Global Transfer Pricing Services, Value Chain Management

KPMG Switzerland

Andreas Wiesner

Director, Global Transfer Pricing Services

KPMG Switzerland

Olivia Gedge

Director, Global Transfer Pricing Services

KPMG Switzerland

Caroline Chua

Director, Transfer Pricing and Value Chain Management

KPMG Switzerland