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Take a holistic approach to business transformation, compliance and controversy management — wherever you operate.
Transfer pricing (TP) services
Local contacts with global reach
Transfer pricing is more than a compliance challenge. It’s a strategic priority. With evolving global tax rules, tighter documentation standards and heightened audit scrutiny, your intercompany pricing is facing pressure from all sides. We help you stay ahead — with insights, technology and strategies that align tax outcomes with your business goals.
With our global network of transfer pricing specialists, we help you build compliant, industry-leading frameworks so you can stay ahead and lead with confidence.
Our offerings
- Reporting
- Global Structuring
- Value Chain Transformation
- Operational Transfer Pricing
- Value Chain Analysis
- Controversy and Dispute Resolution
Reporting
Transfer pricing documentation is no longer just about compliance — it’s about telling a consistent, defensible story. Tax authorities around the world are raising the bar with stricter requirements and deeper scrutiny. Contracts alone won’t cut it. Authorities want to see alignment between your documentation, actual business activity and how risk and control are managed. Today, that means sourcing data from multiple systems, creating consistency across reports and articulating substance — not just structure.
Our global network of transfer pricing specialists can help you:
- Reassess your current transfer pricing policies and make them fit for the future
- Assess gaps in your current transfer pricing documentation
- Create a reporting strategy that can effectively integrate data from different executive departments and operational systems
- Systematically address deadlines and requirements related to transfer pricing and related documentation — from customs reporting to local transfer pricing information returns to country-by-country reporting and OECD guidance related to Amount B and the Pillar Two GloBE information return
- Streamline the process to develop robust, coordinated transfer pricing documentation through our Global Coordinated Documentation™ framework.
Global Structuring
Multinationals face heightened interest in their tax and transfer pricing positions. No longer just of interest to tax authorities, corporate tax positions have moved up the government and public agenda. Tax departments are focused on substance, having the right facts and documentation to support tax positions, and managing their global tax footprint.
We can help you:
- Work on a flexible, future-focused transfer pricing strategy
- Assist with preparations for the significant changes expected from the OECD’s Two-Pillar project and foreign tax reform
Value Chain Transformation
Companies continue to adapt to changing US and global tax policies, like Pillar Two, BEAT, GILTI, FDII and 163(j). Customs considerations and supply chain considerations put additional pressure on getting transfer pricing policies correct and consistent, with a heavier price for retroactive measures. Companies also have to constantly reinvent themselves to adapt to unpredictable economic and geopolitical circumstances. This requires just as much agility from a tax operating model perspective. Our Value Chain Transformation services can help companies integrate tax planning with operating models to develop efficient and innovative strategies around trade, supply chain and digitalization.
Operational Transfer Pricing
Intercompany transactions are under the microscope. With global and US tax reform reshaping expectations, how you structure and manage transfer pricing has never mattered more. A strong operational transfer pricing strategy bridges the gap between policy and execution — bringing tax, controllership, treasury and shared services into alignment. We can help you turn tax complexity into operational clarity — leveraging your existing tech investments to build governance that scales and transforms how intercompany transactions work.
Value Chain Analysis
Transparency and sustainability expectations are rising — and so is the pressure to explain how and where you create value. With public country-by-country reporting gaining traction, companies are facing new scrutiny over profit allocation and transfer pricing resilience. Now more than ever, it’s crucial to understand which activities drive value, how profits are distributed and whether your approach stands up to scrutiny – backed by data and grounded in market realities.
Controversy and Dispute Resolution
We don’t just step in during disputes — we’re with you from the start. Our transfer pricing controversy team is embedded in day-to-day global structuring to help you anticipate risk and prepare for scrutiny. With deep technical experience — and a team that includes former Treasury and IRS officials — we bring insights and relationships that can accelerate resolution and drive better outcomes.
6:59
Asia-Pacific Transfer Pricing Roadshow: Mastering TP in
Asia-Pacific Transfer Pricing Roadshow: Tackling TP in dynamic APAC
PwC’s Brian Burt and Andrew Fairfoull unpack what’s next for multinationals navigating tax complexity across APAC. From Pillar Two reforms and evolving tariffs to regulatory shifts in China, they explore how businesses can take a more strategic, long-term approach. The discussion spans tax-friendly hubs like Singapore and Hong Kong, and why companies should balance patience with bold moves when considering China decoupling or supply chain diversification.
They also dig into emerging value-based fee models in India, Indonesia and Malaysia, and how to build credibility with tax authorities through proactive measures like APAs. Throughout, they emphasize the power of a consistent global tax narrative — and why now is the time to lead with clarity, not react in silos.
A closer look at the simplified and streamlined approach (Amount B)
Take a deep breath and dive deep into the intricacies of Amount B with PwC's extensive Tax Policy Bulletin. Gain key insights from PwC Transfer Pricing Principal Kartikeya Singh's Tax Insights in Brief video and explore our analysis on how Amount B will impact transfer pricing and tax certainty.
3:28
Tax Insights in Brief
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