Transfer pricing

With tax rules worldwide in constant flux, are you able to prove you're compliant in every country where you operate? Do you have the processes in place to determine a coherent price for your intercompany transactions and avoid double taxation?

Your challenges

The world of international taxation rules is in turmoil: the EU’s holding ongoing discussions on fair taxation and the Organisation for Economic Co-operation and Development (OECD) claims that international taxation rules may need revision. Tax authorities are attempting to coordinate the rules, but with different laws in over 170 tax regions and different interpretations of these, transfer pricing (TP) guidelines are shrouded in uncertainty.

As an organisation doing business across borders, TP is a pillar of your corporate governance: your internal controls and decision-making models must shift from effective tax rate to sustainable tax rate monitoring to remain compliant and avoid tax litigation.

How do you achieve this within the tangled web of international taxation rules? Do you have the processes in place to navigate these complexities and avoid double taxation? How do you establish a coherent price for each link in your value chain?

The world of international taxation rules is in turmoil

How we can help

We begin with a comprehensive value chain analysis to understand the functions your organisation is undertaking in each country where you do business. Together,  we’ll take a deep dive into the activities and processes that generate profits across the globe and based on our findings, we’ll help develop a coherent intercompany pricing agreement using TP approaches and tools like benchmarking. 

To avoid double or even multiple taxation in two or more countries on the same profit, we work with local tax authorities to establish an advance pricing agreement (APA). We take these and other measures as required to implement robust corporate governance systems, providing you with the predictability you need to mitigate risk.


Drawing from over 180 solutions using technologies like predictive and descriptive data analytics, artificial intelligence (AI) and robotic process automation (RPA), our network of over 3,200 highly experienced TP specialists across the globe can assist with any TP issue, anywhere.

Find out about our customs and international trade strategy solutions.

Discover how we use automation to streamline your VAT reporting and recovery processes.

Watch the video for details, and to see our Automated Transfer Pricing Compliance Service in action. To request a demo or for more information, don't hesitate to get in touch.

PwC's Automated Transfer Pricing Compliance Service

Save valuable time and resources with PwC’s automated data gathering services. We use the latest automation technology to create multiple transfer pricing documentation reports based on a series of customised, dynamic templates.

Uncover the opportunities hidden in your data

Not only does automation deliver standardised and consistent transfer pricing documentation reports across your organisation, it takes your transfer pricing process one step further: automated data gathering allows you to monitor and make predictions, to reveal hidden opportunities within your transfer pricing data.