Transfer Pricing

Plan, manage and solve complex pricing matters impacting our client’s global operations. Services include resolving disputes and gaining tax certainty, aligning the tax outcomes with value chains, providing solution based economic analysis, and documenting positions to support regulatory requirements.


BEPS Contract Analysis

It is designed to assist clients in drafting intercompany contracts that are consistent with the OECD BEPS requirements on the management and sharing of risks.

Value Chain Alignment (VCA)

(VCA) supply chain planning uses arm’s length transfer pricing guidelines, applied to a center-led business model (that is the Principal Operating Company (POC)), as well as customs and other indirect tax planning to embed tax efficiency into a company’s operating model.


Planning support includes financial modeling, documentation of planning assumptions, and plan transition and reconciliation. Full scope valuation includes expert opinion valuations and indicative valuations (with or without plausibility checks).

Goods & Services

Helps maintain and improve our benchmarking capabilities, which includes TNMM benchmarking technical discussions, search matrices, automatic translation guidance, common standards, and benchmarking databases.

Financial Transactions

Transfer Pricing service line has invested in a framework for delivering transfer pricing debt pricing services in a consistent, efficient, and cost-effective manner.


Country by Country Reporting (CbCR)

In essence, large multinationals will have to file an annual report, the CbC Report, that breaks down key elements of the financial statements by jurisdiction.  Deloitte assists clients in strategically determining the overall approach, constituent entities and associated tax jurisdictions of residence, business activity code selection, financial data sources, definition interpretation, data mapping and the CbC report preparation.

TP Documentation Toolkit

The "TP Documentation Toolkit" is a common framework to deliver transfer pricing documentation reports globally in a consistent, efficient, and cost-effective manner. The TP Documentation Toolkit is scalable and applicable for ALL types of TP documentation projects. Organized by phases, modules, and tasks, the TP Documentation Toolkit provides you with easy access to content, resources, tools and templates in each corresponding task.


Operational Transfer Pricing (TP) Our Operational TP offering (OTP) aligns the areas of a TP lifecycle (plan, manage, and resolve) to facilitate a holistic view of transfer pricing in the business. We have resources to help clients review their current processes, recommend process improvements to the collection and use of data, construct a business case, implement, and monitor their operational transfer pricing.


Dispute Prevention

Our dispute prevention offering provides tools and resources to help clients proactively manage their controversy issues. This includes: planning and preparation to minimize disputes, documenting and preparing evidence and defense files, developing global strategic controversy-aware TP policies, bilateral and multilateral APAs, advanced rulings and unilateral APAs, pre-transaction engagement with tax authorities, and ongoing proactive engagement with tax authorities.

Dispute Resolution

Our dispute resolution offering provides tools and resources to help clients manage their disputes with tax authorities. This includes: transfer pricing inquiry handling and closure, global inquiry process tracking, interaction with tax authorities, economic and technical support, appeal and litigation support, MAP and arbitration support, and diverted profit tax regimes.

Deloitte Technological Solutions

✧ TP Documentation  - TP Digital DoX

TP Digital DoX is Deloitte’s global proprietary web-based application for generating transfer pricing reports for Multinational Enterprises. Its modular approach leverages existing and newly created information to enable flexible collaboration between internal and external users. This web-based solution provides a central project management via an integrated dashboard. It facilitates and streamlines the efficient preparation of TP documentation reports, while enabling collaboration.

✧ CBC Reporting

Deloitte’s MyInsight – CBC Filing Essentials PLUS (aka “CDX smart”) is a proprietary web-based application designed to enable large multinational enterprises to prepare and generate online the necessary filings in accordance with the OECD Country-by-Country (CbC) reporting requirements. CDX smart can be accessed and used by both Deloitte practitioners and client users and aims at facilitating the collection, validation, visualization and conversion of CbC reportable data into ready-for-submission filings.

Operational Transfer Pricing - TP Analytics tool

Our response of how today’s technology can help tax departments to turn data into intelligence and efficiently implement transfer pricing policies. TP Analytics is a custom, interactive, and user-friendly tool which enables to monitor keys financials and perform various analyses such as What-If Scenarios, Profitability Forecasting, Budget Variance Analysis. Our solution enhances process and data management and improves decision making through technology.

The benefits for your business

✔️ A holistic approach to your intercompany arrangements

From planning your intercompany pricing to defending your position in the context of tax audits, Deloitte Greece can be your trusted partner through all phases of the Transfer Pricing cycle.

✔️ Robust documentation

Our meticulous approach and technical expertise will help identify potential issues in time and minimize transfer pricing exposures.

✔️ Taking Transfer Pricing to the digital era

We will help you streamline your operations with the help of digital tools that redefine traditional monitoring processes and transfer pricing documentation.


Get in touch

Fotis Tsamparlis

Fotis Tsamparlis

Partner, Tax & Legal, Transfer Pricing Leader and Industrial Products and Construction Sector Leader

Fotis is a Tax & Legal Partner, the Leader of our Transfer Pricing practice and in charge of the Industrial Products & Construction sector. He has extensive experience in Transfer Pricing Controversy ... More

Vaios Makrygiannis

Vaios Makrygiannis

Partner, Tax & Legal

Vaios is a Partner in the Tax & Legal practice, specialising in Transfer Pricing. With 17 years of experience in tax consulting, both in Greece and the United Kingdom, he has developed extensive exper... More