Transfer Pricing

Optimization, compliance, efficiency and controversy management

Multinational businesses are expanding the volume of related-party transactions and continuously improving their supply chains, which simultaneously has increased the transfer pricing documentation requirements worldwide. Deloitte's transfer pricing professionals can assist taxpayers with their documentation requirements by preparing transfer pricing documentation reports, analyzing the arm’s length nature of the intercompany prices. We have the competence to document all types of transactions including goods transfers, service renderings, financial transactions and intangible property relocations, among others.

Deloitte Transfer Pricing

TP Technology | Deloitte TP Digital DoX

Deloitte TP Digital DoX is a web-based solution to facilitate and streamline the efficient preparation of TP documentation reports, while allowing for close collaboration between and among Deloitte and project teams.

Factual and financial information is gathered via user-friendly online questionnaires, the responses to which are mapped into automatically generated TP Master File, Local File or stand-alone reports following a modular approach.

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About Transfer Pricing

Deloitte has a Global Transfer Pricing Center, that includes employees having on-the-ground international transfer pricing experience in Europe, the Americas and 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. Deloitte can as such assist multinationals with multiple foreign affiliates to prepare global documentation to satisfy all of their documentation requirements in an efficient and consistent basis.

BMO and Transfer Pricing Planning

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. Global transfer pricing rules often require taxpayers to explain the economic foundation and results of their intercompany transactions. 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's transfer pricing professionals can assist taxpayers in reviewing risk allocations in intercompany arrangements within a meaningful industry analysis, deploying the methods and guidance provided in national tax rules and the OECD guidelines. 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. Deloitte can also assist clients in their transfer pricing planning, providing clear and concise transfer pricing policies and other planning-related guidance.

Tax Controversy Management

Deloitte’s controversy and dispute resolution practice include former tax authority officials and alternatively dispute resolution specialists to help companies consistently control and manage transfer pricing tax audits and controversies. We can provide strategic advice and tactical support to businesses in all facets of the tax controversy lifecycle.

Advance Pricing Arrangements

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 has historical knowledge and practical experience with the advance pricing arrangement (APA) process through which we can help companies manage their transfer pricing issues, particularly the risk of double taxation, on a prospective basis.

Dispute Resolution and Mutual Agreement Procedure

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. Deloitte has an experienced team which can assist taxpayers in all levels of the tax authority process, from proposed adjustments by field agents, through APAs, administrative appeals, litigation and the Mutual Agreement Procedure (MAP) process. We assist businesses in preparing for and managing tax examinations. Our services include helping companies review pre-filling agreements and transaction disclosures. We provide assistance with developing technical arguments and drafting advisory opinions, as well as support during court procedures and arbitration advice. We focus on efficiently and cost effectively helping companies address to their individual tax audit needs. Our approach to tax audit management helps businesses enhance access to essential data, expedite responses to information requests and proposed tax adjustments, utilize in-house tax departments and build greater consistency in the information provided to tax authorities.


Elvira Allvin

Elvira Allvin

Partner | Transfer Pricing

    ... Mer

David Godin

David Godin

Partner | Transfer Pricing

   ... Mer