Transfer Pricing

As part of the BEPS project, the OECD has defined new documentation standards. Accordingly, group companies need to prepare master files, local files, and country-by-country reports. The scope of documentation has thus significantly increased on the level of both content and detail. The required content, deadlines, and penalties are country-specific.

We rely on our global network and implement documentation tools developed in-house to support you in analysing existing documentation and setting up newly required documentation. Benchmarking analyses for transactions and profit margins, as well as in-depth analysis of the value chain are used.

The international discussion around BEPS and tax avoidance has increased in intensity. The number of audits focused on transfer pricing has also increased. We support you to implement transfer pricing systems during tax audits and appeals procedures, as well as – to avoid international double taxation – in mutual agreement and arbitration procedures.

Companies in many countries can reach agreements with the tax authorities relating to transfer pricing to establish legal certainty in advance. We use our technical experience, and that of the international PwC network, to conclude agreements of this kind in your interest.