Global Transfer Pricing Services
Transfer pricing is one of the most important issues that businesses must pay attention to when investing in various parts of the world. Tax laws and tax authority’s requirements on transfer pricing may differ from country to country. Knowing the details and trends of transfer pricing policies throughout the world will help businesses make appropriate and adequate preparations in ways that minimize tax risks in order to avoid double taxation as well as reduce compliance burden associated with transfer pricing. As OECD published its final BEPS Action 13 report, countries around the world are starting to make laws based on the transfer pricing documentation suggested in the action plan. Meanwhile, the tax authority of Taiwan has published new amendments to the transfer pricing regulation, which officially incorporates Base Erosion and Profit Shifting (BEPS) Action 13 into Taiwan’s 3-tier transfer pricing documentation framework. These movements require businesses to re-examine their global tax management strategies on a group level, and begin preparing new transfer pricing documents as part of the day-to-day operation. Making the right preparations would help businesses manage taxation costs more effectively on a global setting.
KPMG's global transfer pricing service draws on the expertise of senior tax professionals, financial analysts and economists from a network of independent member firms affiliated with KPMG. Together, they provide professional transfer pricing services to customers around the world in areas that are relevant to their business activities. KPMG's global transfer pricing service team comprises nearly 1500 professionals from different locations and areas of expertise.
We provide the following services
- Transfer pricing advisory
- Transfer pricing document preparation (master file, CbCR, and transfer pricing report)
- Transfer pricing project review and advisory service Global transfer pricing policy review and planning
- Transfer pricing consultation services for tax disputes
- Value chain assessment and the tax optimization analysis of business model under global transfer pricing system
- Review and analyze intangible transactions and the reasonability of profit allocation among affiliated companies in accordance with the regulations stipulated in OECD Guideline and Taiwan transfer pricing regulations.
- In accordance with the updated transfer pricing regulations announced by the OECD or each jurisdiction, review related-party transactions, transfer pricing policies, and the functional and risk characterized position among affiliated companies to mitigate potential transfer pricing risks.
- Review group effective tax rate, profit allocation, transfer pricing policies, and functionally characterized position among each jurisdiction to reduce tax burden globally and provide an optimized global tax strategy.
- Utilize the digital tax technology to evaluate and detect the potential tax risks which might be occurred among Master file, Country-by- Country reporting, and transfer pricing report in order to deliver effective tax risk control solutions.
- Based on the corporate organizational structure, review the current transfer pricing transactions and profit allocation. Furthermore, evaluate the custom duty, business tax, or related tax issues from respective jurisdictions to analyze and provide the best investment tax structure.
- Application for advance pricing agreement (APA) and Mutual Agreement Procedure (MAP)
Meet our team