Global Transfer Pricing Review

Did you know?

• More than 105 countries have implemented CbyC requirements for years 2016-2024.
• More than 80 percent of the countries that have implemented final rules on CbyC requirements require CbyC notifications.
• More than 70 percent of the countries that require CbyC notifications have CbyC notification penalties.
• Approximately 90 percent of the countries that have implemented final rules on CbyC requirements have penalties associated with the CbyC report.
• More than 70 percent of the countries that have implemented final CbyC rules require subsidiaries of a multinational enterprise to file the CbyC report if their parent’s jurisdiction is not covered by a Multilateral Competent Authority Agreement (MCAA) on the exchange of jurisdiction-by-jurisdiction reports.

As of December 2024

A related episode from our Exploring Transfer Pricing podcast.

Did you know?

• More than 75 countries have implemented a Master File for years 2016-2024.
• More than 65 percent of the countries that have implemented a Master File require content consistent with that of the OECD Chapter V. 
• More than 35 percent of the countries that have implemented a Master File require it to be submitted to the tax authority by a certain date.
  • On average, MNEs have approximately 25 days to submit the Master File once requested by a tax authority.
• More than 55 percent of the countries that have implemented a Master File allow it to be submitted in a language other than the local language. 
• More than 85 percent of the countries that have Master File requirements have penalties associated with the Master File.

As of December 2024

A related episode from our Exploring Transfer Pricing podcast.

Did you know?

• More than 70 countries have implemented a Local File for years 2016-2024. 
• More than 55 percent of the countries that have implemented a Local File require content consistent with that of the OECD Chapter V. 
• More than 30 percent of the countries that have implemented a Local File require it to be submitted to the tax authority by a certain date.
  • On average, MNEs have approximately 24 days to do the submission.
• More than 45 percent of the countries that have implemented a Local File allow it to be submitted in a language other than the local language.
• Over 90 percent of the countries that have Local File requirements have penalties associated with the Local File.

As of December 2024

A related episode from our Exploring Transfer Pricing podcast.

Did you know?

Adjustments Penalties:

• Over 105 jurisdictions impose penalties related to transfer pricing adjustments. These penalties can range from fines to more rigorous sanctions such as imprisonment. 

Domestic Transactions:

• More than 70 jurisdictions require taxpayers to include domestic related party transactions in their transfer pricing documentation or Local File.

Tax to Book Differences:

• More than 70 jurisdictions allow taxpayers to file tax return numbers that differ from book numbers.

Advance Pricing Agreements:

• Over 75 jurisdictions have Advance Pricing Agreements programs in place offering unilateral, bilateral or multilateral arrangements.
  •    More than 80 percent of these jurisdictions allow taxpayers to enter into bilateral Advance Pricing Agreements. 

Disclosures:

• More than 90 jurisdictions have Transfer Pricing disclosure requirements. Transfer Pricing disclosure requirements include any information requested related to intercompany transaction data beyond country-by-country reporting/notifications and TP report documentation (i.e.  Master file, Local file, and local Transfer Pricing documentation).  
• Over 95 percent of the jurisdictions that have Transfer Pricing disclosure requirements request taxpayers to fill out specific schedules with details on their related party transactions and submit them along with their tax returns.  

Transfer Pricing Safe Harbor Rules:

• More than 40 jurisdictions have Transfer Pricing Safe Harbor Rules.
• Over 50 percent of the Transfer Pricing Safe Harbor rules relate to interest rate-benchmarking, interest limitation and thin-capitalization. 
• More than 35 percent of the Transfer Pricing Safe Harbor rules relate to pricing of low-value adding services based on a specific markup without having to conduct a benchmarking study. 

As of December 2024