Transfer pricing

Deloitte’s globally-managed transfer pricing team helps companies reduce risks by aligning practical transfer pricing solutions with overall global business operations and objectives, assists with strategic documentation to support transfer pricing practices, and resolves disputes efficiently.

The Complexity Tree

In this 5-part video journey, our Transfer Pricing leaders describe the changing landscape of financial transactions taking place within multinational corporations in what we call the complexity tree.

Transfer pricing advisory and documentation

Multinational businesses are expanding the volume of related-party transactions and continuously improving their supply chains. This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Deloitte provides practical solutions such as strategic approaches to transfer pricing documentation requirements, which help global businesses to achieve their operational and international tax objectives. 

Deloitte has a Global Transfer Pricing Center that includes economists, tax professionals and MBAs who have on-the-ground international transfer pricing experience in Canada and across the globe. Our approach facilitates uniformity of reporting and eliminates internal inconsistencies which can arise from multiple service providers, thereby making our process more effective, efficient and easier to explain to the relevant authorities on your behalf.

Dispute avoidance: Advance pricing agreements

Transfer pricing presents many tax, legal and operational challenges. To many taxpayers the magnitude of uncertainties – including the potential commitment of significant management time in the event of a transfer pricing examination – is not an acceptable business risk. Advance Pricing Agreements (APAs) allow taxpayers to achieve greater certainty via advance agreements on their transfer pricing methods with one or more tax authorities. Deloitte's experience with the APA process spans the development of the national programs and this historical knowledge and insight combined with more recent practical experience helps us help companies to manage their transfer pricing issues – particularly the risk of double taxation – on a prospective basis.

Dispute resolution: Examination defense and mutual agreement procedure/competent authority

Often it is the actions and responses in the initial stages of a tax authority enquiry or interview that affects the course or outcome of a transfer pricing examination. Effective and efficient explanations of business transfer pricing policies include early involvement of an experienced global team that has practical experience with all levels of the tax authority process, from proposed adjustments by field agents, through Advance Pricing Agreements, administrative appeals, litigation and the Mutual Agreement Procedure (MAP) process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP process.

Leverage the powerful combination of former senior CRA officials, top tax litigation lawyers, and pre-eminent specialists in all subject areas of tax, collaborating at all stages to deploy the optimal dispute resolution strategy. Our focus is practical, early resolution, but we have the capabilities to go the distance where litigation makes sense.

Business model optimization

The global economic environment is characterized by continuous improvements in technology, an urgency to adopt and implement best practices and processes, and the potential for legislative change such as Base Erosion Profit Sharing (BEPS), a movement that will address concerns surrounding current principles of national and international taxation that is failing to keep pace with the global nature of modern trading and business models. Assessing a multinational's global business model is no longer an optional exercise. Business Model Optimization (BMO) is the process of understanding the demands of operations and of tax law and integrating them into the business model. Deloitte provides high quality, customized tax and BMO services that focus on helping multinationals integrate operational and tax requirements in a scalable and sustainable way in order to help business leaders to make effective decisions on an after-tax basis.

Deloitte delivers business model optimization services using our proprietary analytics tool known as the BMO Insight methodology, a set of experience based approaches for developing solutions to a range of tax issues and opportunities.