Insight

Global Transfer Pricing Review

Comprehensive information covering more than 100 countries and feedback on more than 200 questions covering local transfer pricing rules and regulations

Transfer pricing is at the core of international trade within multinationals. As a result, it is important to stay current with transfer pricing rules worldwide. KPMG International has developed the Global Transfer Pricing Review to help professionals stay aware of a broad range of valuable and timely information. It is comprised of data collected from transfer pricing professionals across the globe and updated regularly. 

Transfer pricing documentation summaries by jurisdiction

A condensed summary of documentation data offering a snapshot of implementation of country-by-country (CbyC) reporting, Master file, and Local file.

Check back regularly for an updated version of the summary.


Country-by-country Insights

Did you know?

  • More than 80 percent of the countries that have implemented final rules on CbyC requirements require CbyC notifications.
  • More than 65 percent of the countries that require CbyC notifications have CbyC notification penalties.
  • Slightly more than 90 percent of the countries that have implemented final rules on CbyC requirements have penalties associated with the CbyC report.
  • More than 75 percent of the countries that have implemented final CbyC rules require subsidiaries of a multinational enterprise to file the CbyC report if their parent’s jurisdiction is not covered by a Multilateral Competent Authority Agreement (MCAA) on the exchange of jurisdiction-by-jurisdiction reports.

As of May 2022

Master File Insights

Did you know?

  • More than 55 countries have implemented a Master File for years 2016-2021.
  • Approximately 60 percent of the countries that have implemented a Master File require content consistent with that of the OECD Chapter V.
  • More than 35 percent of those countries require the Master File to be submitted to the tax authority by a certain date.
  • On average, MNEs have approximately 30 days to submit the Master File once requested by a tax authority.
  • Just more than 50 percent of countries allow the Master File to be submitted in a language other than the local language.
  • More than 85 percent of the countries that have Master File requirements have penalties associated with the Master File

As of May 2022


Transfer pricing customized reports

Using the significant scope of information found in the Global Transfer Pricing Review, KPMG is able to customize a report for your needs, with such country-specific information as:

  • Transfer pricing audits and penalties
  • Transfer pricing disclosures
  • Advance pricing agreement options and filing fee information
  • Special considerations including the secret comparables and the level of interaction between transfer pricing and customs authorities
  • Exam initial information request and exam information response times.

With our exhaustive data and technology enabled process for updates, we have the ability to create customized reports to fit your specific request. 

Tip: If you would like to receive a version of this report, customized for the countries your company is operating in, contact your local KPMG transfer pricing adviser or request your customized report here.