Transfer Pricing

Transfer pricing refers to all aspects of inter-company pricing arrangements between related business entities, often involving transfers of tangible and intangible property.

"R&D, manufacturing, marketing, distribution - all need to be priced in order to have budgetary equilibrium at a global level."

Isabel Verlinden, Partner & European Transfer Pricing Leader

Transfer pricing is a matter that is of fundamental importance to multinationals. It is vital for every company to have a coherent and defendable transfer pricing policy, which is responsive to the very real climate of change in which companies are operating.
Inter-company transactions across borders are growing rapidly and becoming much more complex. This has resulted in greater vigilance by tax authorities worldwide, which are imposing stricter penalties and new documentation requirements, and engaging in increased information exchanges and increased audit/inspection activity as they become aware of how transfer pricing might affect tax revenues. Compliance with the different requirements of multiple tax jurisdictions can be a complicated, time-consuming task.

By considering transfer pricing practices carefully, multinational businesses can manage risk while improving operational and financial performance based on a long-term view of sustainable growth.

Potential issues

• you need advice on transfer pricing documentation requirements in multiple jurisdictions;
• you are uncertain whether an advance pricing agreement is a better option than defensive documentation;
• you need to respond to a tax authority transfer pricing audit/enquiry
• you are interested in optimally managing your worldwide transfer pricing policies and procedures;
• you don't want to waste valuable management time dealing with transfer pricing audits.

"Finance professionals don't like suprises - and that can be a hard nut to crack."

Patrick Boone, Lead Partner - Transfer Pricing

How PwC can support you

At PwC, we have a strong international network of dedicated transfer pricing specialists with advanced training in economics, accounting and law. Our professionals work together on every engagement, drawing on a global resource pool to identify the appropriate team for each project. This allows us to deliver seamless services covering a wide range of inter-company transactions worldwide.