Multinational corporations are only too familiar with the increasing transfer pricing compliance requirements being imposed by tax authorities in the jurisdictions around the world. In addition to requiring compliance with local transfer pricing rules, tax authorities are also intensifying audit and inspection activity related to transfer pricing. The number of jurisdictions imposing strict penalties for failure to comply with transfer pricing documentation requirements is growing.
Country-by-country reporting requirements could potentially have a large impact on companies operating globally, as it would require detailed information with respect to each entity in a multinational group.
In the face of the increased fiduciary and legal responsibilities that are imposed to comply with specific requirements of multiple jurisdictions, the need for you to have effective and consistent transfer pricing documentation is paramount.
To defend your transfer pricing practices and results you need an efficient and uniform framework for producing the required level of documentation. PwC’s Global Coordinated Documentation (GCD) approach is designed to help you do this. It facilitates the development of robust, coordinated, global transfer pricing documentation, and enables you to determine where to focus your efforts and deploy resources. This will ensure that the specific local country transfer pricing requirements are met, while maintaining consistency among territories.
GCD utilises common data and background information to prepare centralised documentation which will then also be used for local country reports in the jurisdictions that require documentation. By centralising the preparation of a ‘core’ document, as well as creating separate local country reports, you will have more control over, insight in, and confidence in, your transfer pricing documentation at any given time.