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Transfer Pricing

Manage, automate, and streamline transfer pricing documentation

Businesses are under more pressure than ever to find efficient ways of managing Transfer Pricing (TP) documentation. The evolving Organization for Economic Co-operation and Development (OECD) recommendations are being expanded with additional local legislative requirements and tax authorities expecting local detail and exactness when scrutinizing it under audit.

Evolving TP documentation from compliance to value creation

Deloitte helps organizations with the tactical and strategic aspects of transfer pricing documentation. Beyond developing compliant transfer pricing documentation, we collaborate with you to enhance your TP documentation processes and operating model, including balancing internal capabilities with those of Deloitte’s teams, and adopting approaches, tools, and technology that improve efficiency and generate valuable insights.

How do businesses achieve the required localization while maintaining necessary global consistency? Doing this without large resources and cost lies at the heart of the challenge.

Deloitte understands this challenge. 99%* of businesses outsource some of their work, they want to partner with their service provider to divide the work in different ways, be it benchmarking, local country files, functional analysis, master file, or coordination of documentation. To address these needs, our approach is flexible and customized.

With current delivery models, 60%* of global TP decision makers think there is room for improvement in their compliance and documentation process.
 
We recommend starting by looking at the processes and documentation that already exist. Our priority is to get the job done and get it done right. Look at resource levels in each area, existing and needed processes. We will work together with you to review risk levels for jurisdictions, entities, transactions, and assign resources accordingly.
 
By the time we’ve drawn up a plan, we will have considered the expectations and deliverables across all areas. We will provide a clear view of what is needed and recommendations as to how to meet those demands.

Tax authority demands for localized information continues to put pressure on TP teams. 77%* of global TP decision makers disagree that most tax administrations will interpret the proposed changes to the TP Guidelines in a consistent manner. Hence, we find a modular approach, the most efficient way to gain consistency but still allow for local flexibility. For those businesses who are ready, we can translate this into our web-based application that takes some of the legwork out of it.

A modular approach also lets us focus resources on the high value, strategic or significant transactions, rather than an indiscriminate approach. This balance between consistency and localization, with a focus on key areas, supports businesses being audit-defense ready.

The objective is to provide visibility, transparency, and governance globally. Our process allows for real-time information; to meet deadlines, manage risk, and support compliance globally and locally.

Data analytics together with our insights on upcoming policy changes, can mean that adjustments and revisions can occur in real time, rather than retrospectively.

Documentation should go beyond compliance. Once the day-to-day and year-to-year compliance is running smoothly, let’s consider the future. It is known that the potential of TP documentation is not fully realized. This might be to provide a base to work up an audit-ready position, develop policies and standard positions globally, manage and reassure stakeholders, identify potential opportunities and enable creative thinking, provide analytical reviews, produce an executive summary for the management and add value in other ways. We want to help you future-proof your business.

We understand that underlying the challenge of all this is the constant pressure on budget and cost. We look at how we can reduce the global cost of delivery, together with the global tax risk. Ultimately though, your stakeholders aren’t just looking at reduced cost. We need to add value.We work with your teams to build stronger partnerships in the wider business to leverage data and deliver commercial value. The result of our process improvement will be improved quality and availability of data and this can drive significant gains.

Go further than just cost and efficiency gains. Free up talent, leverage the power of data, explore the undiscovered, and find something new.

Discover how Deloitte’s transfer pricing solutions can help your organisation

Our thinking

FS Transfer Pricing Decoded – A global tax podcast series

Financial Services (FS) Transfer Pricing (TP) Decoded is a new podcast series exploring global Transfer Pricing issues relevant to the Financial Services industry. Listen to specialists from across the Deloitte network discuss issues ranging from how we work to how to tackle cost allocations for Transfer Pricing purposes, as well specific Banking, Insurance and Investment Management Transfer Pricing insights. With each episode less than 30 minutes, it’s an easy way to learn about some of the key Transfer Pricing matters that could impact your business.

Delivering insights on transfer pricing controversy

In collaboration with International Tax Review (ITR), Deloitte leaders offer wide-ranging insights for global businesses on the evolving transfer pricing environment, ways to mitigate transfer pricing controversy and proactive strategies to foster efficient resolution of disputes that do arise.

Operations transformation

Business model evolution is accelerating more quickly than ever. Companies are adapting to the digital era, investing in green initiatives and mapping growth plans for recovery. They cannot do all of this without the forecasting and scenario modelling capabilities of their tax team. This creates a new business imperative for the C-suite to partner with the tax function. By no longer being consumed by routine compliance and reporting activities, the tax team is empowered to deliver increased agility and value.
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Global Business Tax

As a global tax leader today, your reality is a fast-changing landscape, from which new ideas, demands, and operating models emerge. Leading through this change and complexity is your priority. And supporting you with this is ours. Learn more about what is new and important in business tax.
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Jeroen Lemmens

Partner, Transfer Pricing