Commonsense Transfer Pricing in a BEPS World

The need for comprehensive and consistent transfer pricing documentation has never been stronger

Vinay Kapoor

Vinay Kapoor

Principal, Economic & Valuation Services, KPMG (US)

+1 212-954-2244
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October 2, 2017 | This What's New in Tax article, the authors provide five leading practices—or "rules of the road"—for approaching transfer pricing compliance.

The Organisation for Economic Co-operation and Development base erosion and profit shifting (BEPS) project, combined with a sharper focus on intercompany fees and allocations by some nontax regulators, is causing multinational companies to reassess their compliance processes and resource requirements.

To navigate this increasingly onerous regulatory environment, multinational companies must take a common-sense approach. This requires having in place efficient processes to analyze, benchmark, document, and defend their related-party transactions. To that end, the following “rules of the road” are described in this article to guide companies in this regulatory environment. 

  • Rule #1: Know Your Transactions
  • Rule #2: Have a Policy in Place
  • Rule #3: Don’t Try to Fit a Square Peg into a Round Hole—Methodologically Speaking
  • Rule #4: Don't Assume Yesterday's Facts are Today's Facts
  • Rule #5: Transfer Pricing Isn't Just About Tax

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TaxNewsFlash—Transfer Pricing

KPMG reports on transfer pricing developments across the globe.