Multinational companies are operating in an environment of unprecedented complexity.  The escalating volume and variety of related party dealings and transfer pricing regimes have resulted in transfer pricing emerging as a major tax planning and compliance issue for multinational companies. 

Transfer pricing determines where, when and to what extent international business profits are diminished by income taxes, customs and other duties.  A multinational company that does not have a well-conceived strategy for the pricing of inter-company flows may be paying too much tax and bearing a high risk of income adjustment, severe penalties and double taxation.

Deloitte can assist you in all phases of transfer pricing planning and in avoiding costly defensive actions.  We have specialist tax professionals and economists focused exclusively on transfer pricing services.  These professionals have extensive experience in helping companies develop and implement transfer pricing strategies that support their overall tax plan and comply with transfer pricing rules.  Our specialists can:

• Perform country-by-country risk assessments to determine whether countries you operate in will accept your transfer pricing method
• Develop a plan for reducing your overall risk and worldwide taxes in the future
• Document your transfer pricing method for all countries of operation
• Show you how to use an Advance Pricing Agreement as a strategic weapon
• Manage all aspects of a transfer pricing investigation or audit by the tax authorities
• Coordinate bilateral and multilateral negotiations with the authorities to reach a globally consistent settlement