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 95 countries have implemented CbyC requirements for years 2016-2022.
  • 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 September 2022

 

Learn more about CbyC Reporting by listening to What Is Country by Country Reporting? Part 1 and Part 2, recent episodes from our Exploring Transfer Pricing podcast.

Master File Insights

Did you know?

  • More than 65 countries have implemented a Master File for years 2016-2022.
  • Slightly more than 60 percent of the countries that have implemented a Master File require content consistent with that of the OECD Chapter V.
  • More than 30 percent of the countries that have implemented a Master File require it to be submitted to the tax authority by a certain date.
    • On average, MNEs have approximately 25 days to submit the Master File once requested by a tax authority.
  • Just more than 55 percent of countries allow the Master File to be submitted in a language other than the local language.
  • Approximately 80 percent of the countries that have Master File requirements have penalties associated with the Master File.

As of September 2022

 

Learn more about Master Files by listening to How Can You Master the Master File?, a recent episode from our Exploring Transfer Pricing podcast.

Local File Insights

Did you know?

  • More than 60 countries have implemented a Local File for years 2016-2022. 
  • Approximately 55 percent of the countries that have implemented a Local File require content consistent with that of the OECD Chapter V.
  • Slightly over 30 percent of the countries that have implemented a Local File require it to be submitted to the tax authority by a certain date.
    • On average, MNEs have approximately 20 days to do the submission.
  • Approximately 45 percent of the countries that have implemented a Local File allow it to be submitted in a language other than the local language.
  • Over 90 percent of the countries that have Local File requirements have penalties associated with the Local File.

As of September 2022

 

Learn more about Local Files by listening to What's the Deal with Local Files and Local Documentation?, a recent episode from our Exploring Transfer Pricing podcast.

Additional Insights

Did you know?

Advance Pricing Agreements:

  • More than 75 jurisdictions have Advance Pricing Agreements programs in place offering unilateral, bilateral or multilateral arrangements.
    •    Over 80 percent of these jurisdictions allow taxpayers to enter into bilateral Advance Pricing Agreements. 

Disclosures:

  • More than 90 jurisdictions have Transfer Pricing disclosure requirements. Transfer Pricing disclosure requirements include any information requested related to intercompany transaction data beyond country-by-country reporting/notifications and TP report documentation (i.e.  Master file, Local file, and local Transfer Pricing documentation).  
  • Over 75 percent of the jurisdictions that have Transfer Pricing disclosure requirements request taxpayers to fill out specific schedules with details on their related party transactions and submit them along with their tax returns.  

Transfer Pricing Harbor Rules:

  • More than 35 jurisdictions have Transfer Pricing Safe Harbor Rules.
  • Approximately 50 percent of the Transfer Pricing Safe Harbor rules relate to interest rate-benchmarking, interest limitation and thin-capitalization. 
  • Over 30 percent of the Transfer Pricing Safe Harbor rules relate to pricing of low-value adding services based on a specific markup without having to conduct a benchmarking study. 

As of September 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.