As transfer pricing (TP) scrutiny intensifies, asset managers face growing complexity and risk. This survey, conducted by KPMG Luxembourg and KPMG US, offers a snapshot of current TP practices and key risk areas across the industry, highlighting how firms worldwide are adapting their models, governance and approach to tax certainty. We would also like to thank all the participants in this edition of the survey for their valuable contributions and openness.
Survey participants
The survey draws on responses from 58 global asset management firms, representing more than USD 37 trillion in assets under management (AuM). Participants include standalone asset managers, bank-affiliated units and insurance groups, operating across major regions such as Europe, the Middle East and Africa (EMEA), the Americas, and Asia-Pacific (APAC). The diversity of asset classes and geographical coverage ensures that the findings reflect both global trends and regional nuances in transfer pricing practices.
Asset class
Key insights by type of transaction
Transfer pricing risk in asset management is not evenly distributed. There are clear pressure points across key transaction types, where complexity, cross-border activity and evolving business models are attracting increased scrutiny from tax authorities.
Understanding transfer pricing audits
Transfer pricing audits have become a common experience for asset managers, reflecting heightened regulatory attention across the industry. The survey indicates a high likelihood of an audit, particularly in relation to financial transactions, regardless of firm size or assets under management.
Audit exposure is especially pronounced among asset managers active in the real estate and alternative investments sectors, where 83% and 67%, respectively, reported having been audited in the past five years. On average, audits take 1.3 years to resolve, suggesting longer, more complex interactions with tax authorities.
Notably, over 9% of audits involved criminal procedures, underscoring the evolving enforcement landscape. While strong documentation and formal compliance are necessary, the findings suggest that complex structures and recent restructurings can significantly increase scrutiny, even where policies are in place.
Advanced Pricing Agreements/Mutual Agreement Procedures developments
Asset managers are increasingly exploring Advanced Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) to achieve greater tax certainty for both taxpayers and tax administrations where different parts of the same transaction or arrangement involving a multinational enterprise are covered by multiple bilateral tax treaties.
While still not widely adopted, the survey indicates a clear increase in APA and MAP activity compared to two years ago, signaling growing interest in long-term stability.
Respondents who have entered into APAs typically operate complex transfer pricing and fee structures, with a particular focus on alternative investment strategies.
What this means for asset managers
Business leaders in asset management face intensifying TP pressure, particularly around cross‑border portfolio management, distribution and financing. The survey highlights frequent gaps in policies, documentation and fee models. Firms may need to revisit governance, test whether remuneration still aligns with value creation and strengthen audit‑ready files.
Against the backdrop of the survey findings, the common avenues explored by the participants and our clients alike are to:
How KPMG can help you today
Are you ready for the questions tax authorities may ask?
Get in touch with our dedicated experts to discuss further survey findings, see how your current approach compares, assess your pricing needs and explore how we can support you in navigating transfer pricing complexity.
