Global Transfer Pricing Documentation
Streamline your global reporting process to maintain compliance and gain proactive planning insights.
Are you wondering if there are blind spots in your global transfer pricing compliance strategy?
Global transfer pricing documentation preparation helps demonstrate that the implementation of existing transfer pricing policies produces arm’s length results, which is key in minimizing the related risks during tax audits. Having a globally organized and centrally managed approach to transfer pricing documentation enhances compliance, but also increases visibility into planning opportunities for your business.
What is global transfer pricing documentation – and why now?
Since the implementation of the Base Erosion and Profit Shifting (BEPS) initiatives by the Organization for Economic Cooperation and Development (OECD), transfer pricing documentation has transitioned from primarily a compliance matter to a fundamental “game changer” where data is used for risk mitigation and formulation of other business strategies.
Further, the BEPS framework aims to modernize tax rules, address the challenges of the digital economy and consolidate unilateral efforts to ensure multinational enterprises pay a fair share of tax wherever they operate.
As a result, multinational enterprises can get buried under the burden of requirements from the OECD, as well as various local country regulations related to transfer pricing. Failure to adhere to global transfer pricing documentation requirements, including master file and local file requirements, can lead to significant penalties for noncompliance and potentially limit taxpayers ability to resolve double taxation issues.
Factors affecting transfer pricing
External forces
There are a number of external forces that influence your need for transfer pricing, including but not limited to:
- Global supply chain changes
- Mergers and acquisitions
- Foreign expansion opportunities
- Legislative changes
Business impact
These external forces will impact your business through:
- Company growth
- New business and transactions
- Strategic integration efforts
- Changes in global tax positions
Strategic transfer pricing compliance and planning
Through a globally cohesive and comprehensive strategy, you receive global consistency with flexibility when and where you need it, a focus on robustness and opportunities, with tailored and personalized assistance.
Benefits of a global transfer pricing documentation strategy
Compliance
Meets desire of OECD and various local countries to have consistent and transparent global reporting regarding multinational group transfer pricing policies
Consistency
A single global provider provides consistency in documentation quality and coordination
Global cost savings
Significant cost savings are achieved by streamlining an organization’s global documentation burden
Increased corporate visibility
Aligning documentation at the headquarter country increases corporate visibility on global transfer pricing policies and potential implementation issues
Proactive management and planning
This is particularly important when trying to drive global value chain alignment by coordinating business and tax planning imperatives
Avoiding penalties
Penalties in certain local countries are potentially significant, both for noncompliance, but also in relation to local assessments that can lead to double taxation
Our approach
Our team of transfer pricing specialists provides tailored and personalized assistance with global transfer pricing documentation, as well as analysis and review, in relation to your business’s global operations. Our globally consistent and regionally flexible approach to transfer pricing is practical and cost effective, all while allowing us to retain focus on robustness and identify planning opportunities.
Transfer pricing value beyond compliance
Baker Tilly offers a unique approach to our global transfer pricing documentation services. We offer proactive planning ideas along the way and can address your most complex business transformation needs, supporting you through your most difficult challenges with tax authorities.
How we help you meet your transfer pricing needs:
Global transfer pricing documentation
- Review and alignment of existing transfer pricing systems and documentation in light of OECD BEPS requirements
- Preparation of transfer pricing documentation reports (master file, local files and other country-specific reports)
- Development of global documentation strategy for multinational enterprises
- Preparation of benchmarking studies
- Local transfer pricing forms and country-by-country reporting
Advisory for transfer pricing-related business processes
- Analysis of processes and development of targets related to transfer pricing within your group
- Transfer pricing implementation support
- Preparation of transfer pricing policies for tangible goods, services, royalties and financing
Transfers of functions and business restructurings
- Examination and classification of relocation of functions from tax and legal perspective
- Transfer pricing design for the avoidance of possibly relocation of functions
- Support in the valuation of intangible property or other transfer packages and determination of compensation payments
Support during tax audits and dispute resolutions
- Development of defense strategies during tax audits
- Preparation of tax opinions
- Support with mutual agreement procedures, advance pricing agreements or tax compliant proceedings
Our professionals
