Transfer pricing policies are of increasing strategic importance and must stand up to the complexities of collaborating tax authorities and greater transparency driven by global tax reform.

So how do you ensure that your business is compliant, efficient and forward thinking in its approach to this increasingly vital element of tax strategy?

KPMG’s Strategic Transfer Pricing practice is dedicated to helping your international business achieve these objectives while preserving value for your business.

We design and implement transfer pricing frameworks that aligns with your business model – and we ensure this is clearly articulated in a manner that minimises dispute risk.

Our solutions are sustainable and aligned with international tax and transfer pricing  guidelines and can help you achieve forward-thinking commercial objectives effectively and efficiently.  

Our Transfer Pricing services

How KPMG can help

We help global businesses like yours prioritise limited resources every day. Here’s how we do it:

Approach

We adopt a forensic approach to understanding your business model and the drivers of business performance to ensure that transfer prices are aligned with commercial circumstances - the best form of defence against challenge from tax authorities.

Planning

We can help your multinational business set transfer pricing policies which act as strategic tools for investment and supply chain decisions and optimise global tax efficiencies consistent with your business model and commercial objectives.

Implementation

We can support your organisation in operationalising commercially sensible transfer pricing policies and we help modify existing policies to reflect changes in local law or business circumstances.

Compliance and documentation

We can design and implement global compliance policies and procedures tailored for your circumstances, and prepare local documentation for a strong, first-line defence against tax authority challenges.

Controversy

We provide strategic and tactical support and solutions to help manage dispute risk. When tax authority challenges arise, we help your business respond with detailed, authoritative economic justifications for transfer prices, and manage competent authority negotiations, arbitration, and litigation support.

We also have extensive experience in negotiating complex Advance Pricing Agreements (APA) and Mutual Agreement Procedures (MAP) between tax authorities.

We bring insight and experience from settling some of the largest transfer pricing cases. We collaborate with KPMG Law who offer legal advice privilege where appropriate.

Economic valuation

Our team includes experienced economists who bring unique insights to both transfer pricing issues and economic valuations.

For our economic valuation work, we combine in-depth knowledge of transfer pricing regulations and valuation concepts to produce economically supportable transfer pricing studies specifically for your circumstance.

Our Transfer Pricing team

The Strategic Transfer Pricing practice is led by three experienced partners supported by a dedicated team of 40 tax advisers, accountants, and economists, providing advice on all aspects of transfer pricing.

We are part of a worldwide network of global transfer pricing services (GTPS) professionals from KPMG member firms around the world who offer experienced local resources and essential local knowledge within a global framework, allowing us to formulate tax-efficient, commercially viable transfer pricing strategies.

Get in touch

We understand the pressures you are under to get it right on Transfer Pricing. You’ll find our approach pragmatic and focussed on the unique circumstances of your business. If you would like to find out more about how we can help please do get in touch.

We look forward to hearing from you. 

Recent Transfer Pricing articles from our Global network

August 2024

27 Aug - Czech Republic: Proposed amendment to legislation introducing top-up tax, implementing EU directive on global minimum tax

27 Aug - Germany: Proposed investment tax incentives, Pillar Two changes, intra-group financing transfer pricing guidance, MLI law enacted

26 Aug - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on India and South Korea

23 Aug - Australia: Proposed amendments to legislation implementing Pillar Two global minimum tax rules

22 Aug - Australia: Legislation implementing Pillar Two global minimum tax rules passes House of Representatives

21 Aug - KPMG report: Potential effects on businesses of new UN tax treaty

19 Aug - Channel Islands: Pillar Two draft legislation published (Jersey)

16 Aug - KPMG report: Reassessing operations in Mexico due to maquila tax regime changes

12 Aug - OECD: Transfer pricing framework for lithium

8 Aug - Austria: Amendments to Pillar Two draft legislation and loss carryforward rules published

8 Aug - Turkey: Draft legislation implementing Pillar Two submitted to Parliament

7 Aug - Australia: Updated guidance on petroleum resource rent tax implements gas transfer pricing review recommendations

6 Aug - Korea: Further proposed amendments to Pillar Two rules

6 Aug - UAE: Tax authority’s policy on issuing clarifications and directives, including advance pricing agreements

5 Aug - Australia: Senate committee report on public country-by-country reporting bill

2 Aug - EU: Public consultation on template and formats for public country-by-country reports

1 Aug - Belgium: Updated transfer pricing forms

1 Aug - UK: Draft legislation implementing Pillar Two country-by-country reporting safe harbor anti-arbitrage rule

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