Manage: TP Documentation

The international transfer pricing governance lifecycle

Having a globally consistent view of your tax data is a continuous challenge for leaders of multinational companies. We leverage best practices to help you develop an effective framework that will increase the global consistency of your transfer pricing data across all of your operations.

The days of writing a long one-off transfer pricing report to leave on the shelf, only to pull off in the event that there is a tax audit are past.

Transfer Pricing compliance requirements are now many and detailed with annual requirements to have written documentation in place and for filings to be made.  For many global businesses this can result in a time consuming exercise to meet local annual requirements without clarity on whether this is managing risk, a lack of consistency in what is being said to different tax authorities and inefficient manual processes.

Deloitte has developed a methodology which navigates these requirements through the use of a modular approach to drive consistency and efficiency, country risk assessment to focus effort on the right areas.

The five essential building blocks for your transfer pricing (TP) lifecycle

Your transfer pricing (TP) control framework starts with a global documentation process

Brochure: Transfer Pricing Documentation Master File

A global strategic imperative

While Country-by-Country Reporting (CbCR) has received the bulk of the attention from the OECD's Action 13 guidance, an accompanying requirement of the three-tiered approach, the Master File, may actually pose greater challenges for multinational corporations.

The Master File requires a deeper level of reporting (with potentially more sensitive data) and will be directly disclosed to countries where multinationals do business.

Learn more about how Deloitte can help

Deloitte Exclusive Transfer Pricing Documentation Summary Guide

This comprehensive matrix represents a compilation of essential CbCR and documentation (including master file and local file where applicable) information for 56 jurisdictions around the world.

It has been reviewed and updated as of March 20, 2018.

Global Tax Reset: Transfer Pricing Summary

Key contacts

Clive Tietjen

Clive Tietjen


Clive leads the Deloitte UK transfer pricing practice outside London. He has significant experience in helping businesses manage their transfer pricing risk through the structuring of arrangements whi... More