Transfer Pricing

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 Centre, 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 centralised 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 propriertary 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. Advanced 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 MPA/CA process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the Mutual Agreement Procedure (MAP)/Competent Authority (CA) process. Our teams include transfer pricing MAP/CA specialists from both countries in dispute teamed with professionals who specialise 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 Optimisation

The global economic environment is characterised 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 Optimisation (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, customised 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.

Pillar Two

Pillar Two sets out global minimum tax rules to ensure large multinational businesses pay a minimum effective tax rate of 15% on profits in all countries they operate in. Deloitte Ireland, utilising its global network and bespoke solutions, is well equipped to assist in all matters Pillar Two.

Read more about Deloitte's Pillar Two service offerings and its team here.