Perspectives

Global Tax Reset: the changing world of tax

The Global Tax Reset is bringing in a new era of international tax, with an emphasis on transparency, consistency and sharing of information between tax authorities. This paper discusses the forces driving significant change to the international tax landscape, as well as key areas of business impact and resulting challenges.

Analysis

The Link Between Transfer Pricing and Customs Valuation - 2016 Country Guide

The authoritative “Link Between Transfer Pricing and Customs Valuation - 2016 Country Guide" compiles essential information regarding customs-related requirements and implications of related party pricing adjustments in key jurisdictions around the world. 

Insights

Deloitte tax@hand

The Deloitte tax@hand global app delivers real-time tax news and updates. Articles are available in English and local language. Make the app your own by customizing it to your countries and topics of interest. Deloitte tax@hand puts the news, tax rates and resources you need at your fingertips.

Insights

Deloitte International Tax Source

DITS allows users to view and compare tax information for different jurisdictions, including tax rates and other information of interest to multinationals. The new, mobile-friendly version features jurisdiction-specific pages linking to relevant DITS content, and easier search results navigation.
Transfer pricing

Services

Transfer pricing

Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The goal of Deloitte’s transfer pricing network is to help companies manage risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results.

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 Europe, the Americas or the Asia Pacific regions. This centralized global approach facilitates uniformity of reporting and eliminates internal inconsistencies which can arise from multiple service providers, thereby making the process more effective, efficient and easier to explain to the relevant authorities.

To deliver transfer pricing documentation services Deloitte has a Global Dox Insight methodology. This is powered by TP Search Smart technology, streamlining the gathering and processing of data and information needed to make informed business decisions.

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 enquiries or interviews that affect the course or outcome of a transfer pricing examination. Accordingly effective and efficient explanation of a business transfer pricing policies include early involvement of an experienced global team that has  practical experience of all levels of the tax authority process, from proposed adjustments by field agents, through Advance Pricing Agreements, administrative appeals, litigation and the MAP process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP process. Our teams include transfer pricing MAP specialists from both countries in dispute teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state/provincial jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome.

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. 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 the BMO Insight methodology, a set of experience based approaches to developing solutions to a range of tax issues and opportunities.

More topics

Services

Tax services

Business tax, International tax, Transfer pricing, Tax management consulting, Mergers and acquisitions – tax, Research and development and government incentives, Deloitte Private, Indirect tax, Global employer services and Business Process Solutions

Todd Wolosoff

Global Managing Director – Transfer Pricing, DTTL

Careers

Join our leading practice as a Transfer Pricing specialist

Join our team as a transfer pricing specialist. As a member of our rapidly expanding transfer pricing practice, you'll use your influence to consult with multinational companies on pricing cross-border transactions.