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Transfer Pricing Documentation

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 scrutinising it under audit.

Evolving TP documentation from compliance to value creation

Deloitte helps organisations 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 localisation 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 co-ordination of documentation. To address these needs, our approach is flexible and customised.

Download Deloitte’s Transfer Pricing Documentation Summary to get a quick view into country-by-country (CbC) reporting and documentation around the world.

Learn more about Operational Transfer Pricing and how Deloitte can help you

A successful process will include:

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 localised 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 localisation, with a focus on key areas, supports businesses being audit-defence 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 realised. 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.

Transfer Pricing Documentation powered by technology

Technology is important for delivering the efficiency and consistency required to meet stakeholder, organisational and regulator expectations. Deloitte can work with the TP documentation tool you already use, or we can leverage our own global proprietary web-based application, TP Digital Dox, to generate transfer pricing reports.

Combining the capabilities of Deloitte’s network with yours and harnessing powerful solutions for global TP documentation report preparation, we can increase the business value your transfer pricing activities delivers today while positioning your organisation to meet the challenges of tomorrow.

Leverage existing reports through a technology-enabled modular approach for efficient and consistent report generation.

TP Digital DoX uses a modular approach to leverage existing and newly created information which can enable flexible collaboration. This web-based solution provides a central project management via an integrated dashboard. It facilitates and streamlines the efficient preparation of TP documentation reports.