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      Rizwana Tahiri and Chris Rogers conclude our series on ERP and tax, by exploring the case for bringing transfer pricing into transformation projects.

      ERP transformation is high on the business agenda, and transfer pricing (TP) is increasingly part of the discussion – for a number of reasons.

      Among leaders’ key questions when designing or upgrading ERP systems are which taxes to include, and how to integrate them. Best practice is to include all major areas, such as direct and indirect taxes, Pillar 2 requirements and transfer pricing.

      What’s more, getting transfer pricing right is one of many Pillar 2 compliance challenges facing tax leaders. And more widely, the tax transparency agenda driving BEPS is pressurising them to ensure their transfer pricing documentation, accounting and reporting are accurate and complete.

      Meanwhile, ERP transformations are increasingly designed to include tax sensitisation, and build future-ready tax functions. As such, they’re featuring a growing range of transfer pricing functionalities for firms to take advantage of.

      Rizwana Tahiri

      Director, Global Compliance and Transformation, Tax & Legal

      KPMG in the UK


      Chris Rogers

      Partner, Global Compliance and Transformation, Tax & Legal

      KPMG in the UK


      TP or not TP?

      In this context, tax leaders often ask us whether they should handle transfer pricing within their company’s ERP system.

      The right answer will depend on several factors: the group’s structure and transfer pricing model; the effectiveness of its transfer pricing compliance and reporting processes; and the cost of implementation. In particular, the more complex the group structure and transfer pricing model are, the more compelling the case for managing transfer pricing within the ERP platform.

      As a rule, incorporating transfer pricing will offer advantages on three fronts.

      Firstly, value. With the ERP tackling transfer pricing, your tax team can stand back and consider the bigger picture and strategic priorities – such as assessing transfer pricing policy, and looking holistically at the results being reported.

      Secondly, risk. Automating transfer pricing calculations will reduce the possibility of manual intervention and human error. In addition, integrating your transfer pricing processes and data within the ERP will mean better transparency and auditability.

      Thirdly – and perhaps most significantly – efficiency. Designing transfer pricing into your ERP transformation upfront will be easier and cheaper than ‘reverse engineering’ it into the system later on. And it will ease your decision-making process, from sourcing and supply chain to transportation and logistics, with clear transactional tax determination.


      From decision to delivery

      If the optimal route is to integrate transfer pricing into the ERP, then tax leaders’ next question tends to be: ‘How’? Understandably, many of them see the system as a black box that’s beyond their sphere of influence.

       Operationalising transfer pricing within the ERP platform is typically a four-stage exercise:

      • Do the groundwork

        Scope out the business, functional and data requirements for the ERP.

      • Make the design decisions

        Select the modules needed to run your transfer pricing processes within the ERP.

      • Conduct a fit-gap analysis

        Identify which requirements can be met by the target ERP architecture, and which can’t. And work out what adaptations will be needed to bridge the gaps.

      • Create the technical documentation

        Distil the outputs from stages 1-3 into design and configuration documents, for developers to use when configuring the ERP.

      Tax teams won’t be able to complete these steps without expert support. Our technology, tax, and transfer-pricing teams can help. We’ll work with you to make your key design decisions and set up the ERP to efficiently deliver your transfer pricing operations.


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      Rizwana Tahiri

      Director, Global Compliance and Transformation, Tax & Legal

      KPMG in the UK

      Chris Rogers

      Partner, Global Compliance and Transformation, Tax & Legal

      KPMG in the UK



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