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Transfer Pricing Documentation

Managing, automating and streamlining Transfer Pricing documentation

Companies are under more pressure than ever to find efficient ways to manage Transfer Pricing (TP) documentation. The evolving Organisation for Economic Co-operation and Development (OECD) recommendations are being expanded to include additional local legal requirements and tax authorities expect local detail and accuracy in auditing.

Evolving TP documentation from compliance to value creation

Deloitte helps organisations with the tactical and strategic aspects of transfer pricing documentation. In addition to developing compliant transfer pricing documentation, we work with you to improve your TP documentation processes and business 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 companies achieve the required localisation while maintaining the necessary global consistency? The biggest challenge is doing this without a lot of resources and costs.

Deloitte understands this challenge. 99%* of companies outsource part of their work, they want to work with their service provider to distribute the work in different ways, whether it's benchmarking, local country files, functional analysis, master file or co-ordination of documentation. To meet these needs, our approach is flexible and tailor-made.

Download Deloitte's Transfer Pricing Documentation Summary for a quick overview of country-by-country (CbC) reporting and documentation around the world.

A successful process includes:

With today's delivery models, 60%* of global TP decision-makers believe there is room for improvement in their compliance and documentation process.

We recommend starting by reviewing the processes and documentation that already exist. Our priority is to get the job done and get it right. Look at the resource levels in each area, existing and needed processes. We will work with you to assess the risk levels for jurisdictions, entities and transactions and allocate resources accordingly.

By the time we have a plan in place, we have taken into account expectations and deliverables in all areas. We will provide a clear picture of what is needed and make recommendations to meet those requirements.

Tax authorities ask for localised information, this continues to put pressure on TP teams. 77%* of global TP decision-makers do not agree that most tax authorities will interpret proposed changes to TP guidelines in a consistent manner. Therefore, we believe a modular approach is the most efficient way to achieve consistency while allowing local flexibility. For companies that are ready, we can translate this into our web-based application that takes some of the work off their hands.

A modular approach also allows us to focus our resources on high-value, strategic or important transactions, rather than an arbitrary approach. This balance between consistency and localisation, with a focus on key areas, supports companies ready for Audit-defence.

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

Data analysis combined with our insights into upcoming policy changes can mean that adjustments and revisions can happen in real-time, rather than retroactively.

Documentation should go beyond compliance. Once daily and annual compliance runs smoothly, let's look to the future. It is well known that the potential of TP documentation is not fully exploited. This may be to provide a basis to develop an Audit-ready position, develop policies and standard positions globally, manage and reassure stakeholders, identify potential opportunities and enable creative thinking, provide analytical assessments, prepare a summary for management and add value in other ways. We want to help you future-proof your business.

We understand that at the root of this challenge is the constant pressure on budget and costs. We are looking at how we can reduce global delivery costs along with global tax risk. At the end of the day, though, your stakeholders aren't just looking at lower costs. We need to add value.

We work with your teams to build stronger partnerships across 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 yield significant gains.

Go beyond cost and efficiency gains. Free up talent, harness the power of data, explore the undiscovered and find something new.

Transfer Pricing Documentation enabled by technology

Technology is important for delivering the efficiency and consistency needed to meet the expectations of stakeholders, organisations and regulators. Deloitte can work with the TP documentation tool you already use, or we can use our own global web-based application, TP Digital Dox, to generate Transfer Pricing reports.

By combining the capabilities of Deloitte's network with yours and using powerful solutions to prepare global TP documentation reports, we can increase the business value delivered by your Transfer Pricing activities today while positioning your organisation to meet tomorrow's challenges.

Leverage existing reports through a modular, technology-based approach to generate reports efficiently and consistently.

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