Plan: TP Consulting

Trends in Transfer Pricing: Global Research Bulletin

In this 2018 global study, Deloitte recently commissioned an extensive, global, independent research to understand emerging Transfer Pricing trends. The study participants included top tax decision makers from multinational companies with revenues in excess of $1 billion USD.

The research has revealed three major trends:

1. Centralization: A trend towards greater centralization in transfer pricing operations. It was acknowledged that the pace and degree of centralization was likely to vary considerably between businesses.
2. Consolidation: Increased market share for the Big Four firms is a steady, pervasive trend, however the market still seems highly complex and individualized to each businesses intended approach.
3. Specialization: Businesses want more than "off the shelf" solutions including tailored advice and innovative ideas across supply chain, intellectual property, legal, and indirect tax.

International tax review: The 2017 global transfer pricing intangibles guide

The global transfer pricing practice worked in cooperation with the International Tax Review to publish a collection of articles on different aspects of transfer pricing particularly focused on intangibles.

As OECD's transfer pricing guidance in Actions 8, 9, 10, and 13, issued as part of the Base Erosion and Profit Shifting (BEPS) Project, continue to take center stage in transfer pricing planning and documentation multinationals face new challenges with respect to the transfer of intangibles. In this guide, Deloitte's transfer pricing leadership team provides valuable insights into some of the most significant challenges that multinational corporations need to overcome in identifying and assigning value to intangibles.

This collection of three short articles includes:

1. Applying the profit split method: Alan Shapiro, Eunice Kuo, and Anis Chakravarty of Deloitte discuss the OECD’s new discussion draft.
2. The OECD hard-to-value intangible guidance: Philippe Penelle of Deloitte Tax LLP looks at the lessons learned from the US commensurate with income standard.
3. Value chain analysis–the role of operating leverage: Shanto Ghosh, Arindam Mitra, and Philippe Penelle of Deloitte Tax LLP examine the role of operating leverage.

The Link Between Transfer Pricing and Customs Valuation

The 2017 Country Guide

This comprehensive document is one of the most broad-based and authoritative annual guides of its kind. The guide features a compilation of essential information regarding customs-related requirements and implications of related party pricing adjustments in key jurisdictions around the world.

The guide has been recently expanded to include Croatia and Slovakia, new contributing countries of increasing interest to multinationals, bringing the total number of countries included to 53. Additionally, this year's responses have been updated to address several country-specific regulatory and enforcement changes and advancements impacting related party customs valuation. The information contained in this guide has been provided by local country specialists from Deloitte's global network of Customs and Global Trade (CGT) professionals.