Transfer pricing for financial services

Timely topics in transfer pricing from experienced professionals, who focus on transfer pricing for financial services companies, but are also taking a big picture view of today’s issues and the implications.


Maggie Fritz

Maggie Fritz

Principal, Economic & Valuation Services, KPMG LLP

+1 212 872 7882

Enrique Martin

Enrique Martin

Principal, Economic & Valuation Services, KPMG US

+1 212 872 6817

Sherif Assef

Sherif Assef

Principal, Economic & Valuation Services, KPMG US

+1 212-954-1937

Kenneth J. O'Hara

Kenneth J. O'Hara

Principal, Tax, Economic & Valuation Services, KPMG US

+1 617-988-5638

The financial services industry continues to experience rapid changes. Digital transformation is gathering pace in many parts of the business and regulations continue to evolve. As a result of these changes, companies within the financial services industry are changing the way they operate through a mix of investment in technology and data analytics, enhanced risk and capital management frameworks, and a focus on efficient infrastructure. 

In parallel with the business changes, the tax environment continues to evolve as initiatives such as the OECD’s BEPS initiatives change the transfer pricing rules and tax authorities continue to evolve their views on transfer pricing. The combination of these changes is creating significant transfer pricing challenges for the industry as transfer pricing policies need to be adapted to new business models. 

Our value lies in the strength of our transfer pricing professional and their experience working with our diverse client base. Our global network positions us to assist our clients in recognizing opportunities and taking actions in response to industry, marketplace, and regulatory changes.

  • What's at risk
  • Industry considerations
  • KPMG can help

What's at risk

  • Transfer Pricing remains a key focus of tax authorities around the globe
  • Taxpayers need to show their transfer pricing policies are in line with evolving regulations 
  • Failure to comply with transfer pricing regulations can result in double taxation, penalties and significant internal resources being used in resolving disputes

Industry considerations

  • The governing regulatory framework needs to be considered when designing/documenting transfer pricing policies
  • The sector often has complex transactions that need robust documentation (e.g., reinsurance, asset management, global trading profit splits)
  • Intercompany transactions may also need to meet regulatory requirements
  • Regulators, and tax authorities, are increasingly looking beyond transfer pricing policies and questioning processes, controls and governance
  • Documentation processes need to keep up with business change

KPMG can help

KPMG professionals have extensive experience in the unique complexities of financial services companies. We specialize in transfer pricing services for all financial service sectors including: Depository Institutions, Advisory, Custodians, Financial Technology (FinTech), Insurance, Investment Management, Alternative Investments, and Specialty Finance & REITs. KPMG can assist with transfer pricing documentation and planning, value chain analysis, dispute resolution, operational transfer pricing and regulatory issues.

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Additional resources

Navigating Transfer Pricing in the World of Alternative Investments
September 3, 2021 | This article explores the evolution and current state of transfer pricing for alternative investment firms and funds. | Bloomberg Tax