Deloitte Transfer Pricing and CbC Data Analytics

In our experience, Transfer Pricing (TP) disputes continue to be one of the leading reasons for controversy between tax authorities and multinational companies. OECD's Base Erosion & Profit Shifting (BEPS) project has put an increased emphasis on transparency and consistency. These new developments coupled with inefficient monitoring and analysis of transfer prices, and deviations from internal corporate policy in implementation, may increase the possibility of double taxation, tax penalties, and/or transfer pricing audits. Deloitte leverages advanced analytics capabilities, deep transfer pricing knowledge and broad technical experience to help turn data into knowledge and actionable insights.

Transfer Pricing & CbC Data Analytics

Key features:

Transfer pricing & CbC data analytics help identify potential opportunities, anomalies, inconsistencies, trends, and risks in large volumes of transactions by delivering:

"Hindsight": Assessing profitability by legal entity, by business unit, by SKU, and determining requisite TP adjustments prior to year-end

"Insight": Enabling root cause analyses for deviations from TP policies/targets

"Foresight": Facilitating predictive transfer pricing, scenario analysis, and integration with indirect taxes

Deloitte's TP & CbC data analytics service offerings:

TP Insite Smart: TP Insite Smart is implementable with individual ERP platforms, a combination of ERP platforms or other data source systems. Through this service offering, users can benefit by automating and accelerating existing time- and resource-consuming transfer pricing monitoring and data analysis processes; thereby, enabling limited internal resources to focus on more value-added tasks. TP Insite Smart helps to turn data into knowledge and actionable insights, including:

• Gaining transactional level insight (down to the SKU level) into intercompany transactions
• Monitoring transfer pricing policy implementation across transactions and entities on a regular basis
• Enabling root-cause analyses of deviations from transfer pricing policies/target and determining corrective actions
• Assessing tax impacts of TP adjustments and underlying indirect tax implications
• Facilitating what-if scenario analyses
• Enhancing visibility and control over TP audits and year-end adjustments

CbC Insite Smart: Cbc Insite Smart helps to gather, monitor and analyze CbC-required data across countries and entities on a regular basis. CbC Insite Smart key features include:

• Automation and standardization of data extraction and transformation for the CbC reporting process, including country-by-country reports formatted per OECD Guidelines
• Standard and custom reporting that allow organizations to monitor CbC data across countries and entities on a regular basis
• Optional drilldown analytics to facilitate root–cause analyses of deviations from policies/target and determine corrective actions