KPMG report: Practical transfer pricing compliance in a complex world

Complexity of today’s transfer pricing environment, suggestions for multinational corporations

Complexity of today’s transfer pricing environment, suggestions for MNEs

Since the introduction of modern transfer pricing rules in the 1990s, there has been an explosion of regimes worldwide. This has made navigating the transfer pricing environment significantly more complex for multinational enterprises. The changes in law and related guidance have been accompanied by greater scrutiny and enforcement by tax authorities worldwide, and increasingly also by penalties for noncompliance.

Whereas 20 years ago generally only the largest multinational enterprises (MNEs) paid significant attention to transfer pricing, today MNEs large and small have no choice but to devote significant resources to transfer pricing compliance. Moreover, changes in the compliance and enforcement environment show no signs of stopping.

Read a May 2023 report* [PDF 270 KB] prepared by KPMG LLP tax professionals that explores the complexity of today’s transfer pricing environment and provides suggestions for multinational corporations to take a practical, commonsense approach in analyzing, benchmarking, and defending their related-party transactions.

*This article originally appeared in Tax Notes International (15 May 2023) and is provided with permission.



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