Transfer pricing for industrial manufacturing

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


Bob Alltop

Bob Alltop

Managing Director, Tax – Economic & Valuation Services, KPMG US


The industrial manufacturing sector of the economy is experiencing unprecedented change.  In the wake of the COVID-19 pandemic, supply chains have been disrupted and companies are balancing the pressures of increased costs.  In addition, the digital economy is transforming how manufacturers add value to their customers, enhance their manufacturing processes, and use data analytics to remake their business. 

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

What's at risk

The pace of change in the marketplace is matched by new developments in global tax policies.  Potential tax reform in the United States and many key trading partners -- combined with multilateral changes brought about by the OECD’s BEPS initiatives -- put transfer pricing in the spotlight as manufacturing companies address the challenges of new business models and tax regulations. Given the long lives of tangible manufacturing assets, combined with the rapid pace of change in the know-how and software that enhance their value, industrial manufacturing companies must strategically analyze the implications of transfer pricing.  Significant supply chain and tax inefficiencies can result from investment decisions in new physical plants and the intellectual property essential to them if the structuring and impact of intercompany pricing are not carefully considered.

Industry considerations

Key to meeting the needs of this changing environment is developing transfer pricing policies and procedures that are as adaptable and ready for change as industrial manufacturers and their supply chains must be. KPMG assists its manufacturing client in employing the right tools for implementing, monitoring, updating, and documenting global pricing.  KPMG assists clients in creating efficient processes, templates, and software to effectively manage global transfer pricing.  Just as our clients are using technology and data to streamline and optimize their businesses, we employ similar approaches to maintain transfer pricing structures that can evolve with a changing business.

KPMG can help

The KPMG Global Transfer Pricing Services practice brings value to companies in facing these changes.  We focus on crafting practical and globally-coordinated solutions to intercompany pricing challenges. From planning, to creating and implementing pricing policies, to documenting and defending these prices, KPMG brings the experience and depth needed to support any manufacturing company.   

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