Trends in Transfer Pricing

Executive summary

Businesses are looking to increase control over their Transfer Pricing positions in order to minimize risk. They are becoming more centralized, focusing on process standardization and consistency, and seeking technology-enabled solutions. Forward-thinking companies are taking a strategic approach to Transfer Pricing. They are rethinking their processes, technology choices, and management philosophy of Transfer Pricing activities to better match today’s evolving tax landscape.

Key findings

• The pace of change in the Transfer Pricing world appears to be accelerating as a result of commercial globalization and the OECD’s Base Erosion and Profit Sharing (BEPS) initiative.
• New regulations and fear of inconsistent application of existing laws are driving risk concerns.
• Growing resource challenges stem from both the increased volume of work and the relatively limited number of qualified Transfer Pricing professionals.
• There are low levels of satisfaction with the current approach to Transfer Pricing, a high degree of uncertainty, and no single, proven model for success.
• Nearly all survey respondents indicated that their organizations rely, to some degree, on outsourcing and anticipate an increasing need for more specialist Transfer Pricing resources, through both in-house recruitment and increased outsourcing.
• The trend towards global coordination and centralization is rapidly increasing.
• Overall, there is a desire to better leverage technology and increase process automation.
• This global research bulletin provides a snapshot of the current state of Transfer Pricing as well as anticipated future trends.