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Transfer Pricing

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Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses.  

Transfer pricing has emerged as a critical success factor in corporate strategic planning and executive decision-making. Companies focused on growth and market leadership have recognized the important role transfer pricing can play in addressing the corporate tax burden, enhancing operational performance, reducing tax compliance exposure and increasing cash flow. It is an international tax issue of significant interest and impact. Many countries follow the U.S. lead in challenging companies on their transfer pricing activities and imposing onerous penalties on those in noncompliance.

Our transfer pricing professionals can assist you in all phases of transfer pricing planning and in avoiding costly defense actions. We can work with you to develop an effective, integrated global strategy for managing the many complex issues involved with moving goods, services and other intangibles across borders. As regulations tighten and penalties increase, now is the time to act—to get your company’s transfer pricing program in order and to aggressively address this major tax issue facing global companies.

The globally-managed Deloitte transfer pricing network helps companies manage risk by aligning practical transfer pricing solutions with overall global business operations and objectives and assisting with documentation to support transfer pricing practices and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results. Our services include:

Transfer Pricing Planning and Documentation 

Deloitte's transfer pricing professionals assist taxpayers with home country and foreign documentation requirements by preparing transfer pricing documentation reports that analyze the arm’s length nature of their intercompany prices. We can also assist multinationals with multiple foreign affiliates to prepare global documentation satisfying all of their documentation requirements in an efficient and consistent basis. Learn more.

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Dispute Avoidance: Advance Pricing Agreements (APAs) 

Deloitte's transfer pricing professionals assist clients with all aspects of defending their transfer prices before the tax authorities and with local audit teams. If an audit results in a transfer pricing adjustment, Deloitte helps obtain double tax relief through the tax treaty competent authority process. Deloitte also helps clients negotiate Advance Pricing Agreements (APAs) to obtain prospective transfer pricing certainty. Learn more.

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Dispute Resolution: Examination Defense and Mutual Agreement Procedure/Competent Authority (MAP/CA)

Deloitte works with clients to explore strategic opportunities to enhance global tax and treasury planning, by aligning the relationship between the taxpayer’s value drivers and income/cost streams to improve their effective tax rate (ETF). This can include supply chain and intellectual property strategies and global charges. Deloitte's services help integrate operational and tax planning in a way that allows clients to treat tax as another cost of doing business making strategic decisions on an after tax basis. Learn more.

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Business Model Optimization (BMO) 

In light of today’s dynamic global economic environment and the potential for legislative changes, assessing a multinational’s global business model may no longer be an optional exercise. Deloitte’s Business Model Optimization (BMO) team provides high quality, customized tax and business model transformation services. With its focus on helping multinationals integrate their operational and tax planning in a scalable and sustainable way, BMO aims to enable business leaders to make more effective decisions on an after-tax basis. BMO is an approach for creating value through business transformation. Learn more.

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As used in this document, “Deloitte” means Deloitte LLP and its subsidiaries. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.


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