Addressing transfer pricing during a transformation project

As the world in which we operate continues to change, business restructuring can offer a way for your companies to gain competitive footing. In such business transformation, every level of the organization is involved, and the implications - operational, tax and legal - are wide in scope and impact.

Transfer pricing revisited

Companies are looking at ways to develop and implement an effective and efficient value chain that considers and brings all facets together to help achieve smoother operations, greater profitability and more sustainable growth. A new organizational setup often implies that your transfer pricing policy and calculation mechanics need to be revisited.

Transformatie Transfer Pricing

Extensive experience with business restructuring

Our transformation team has extensive experience with business restructuring. We operate as one team with specialists from our international tax services, transfer pricing, indirect tax (incl customs and trade), P&O and advisory departments. As a team, we support you in shaping your business aligned with your company’s core business, ongoing business developments, and strategies at the global and country levels.

A clear and flexible organisation

The tax and transfer pricing setup around your new organisation should be clear and flexible for future expansion, including acquisitions. PwC’s transfer pricing experts can support you during the whole process of transformation, including assistance with key questions such as: How can you tax optimise your new setup? How should you define your transfer pricing policy? How should you manage exits from countries and discussions with authorities?

Transformatie Transfer Pricing

How we can help

Our experienced transfer pricing team can assist you with:

  • designing the new organizational structure, aligning with business needs.

  • designing the new ways of working together with the business.

  • adapting the finance processes to the new structure.

  • defining the new transfer pricing policy.

  • performing the conversion analysis and setting strategy to optimise fiscal position.

  • defining a controversy strategy. Will you request for advance pricing agreements or will you prepare for a tax audit strategy? Both require upfront documentation that we will assist you with.

  • designing a transfer pricing monitoring process fit for the increased challenges by external auditors and tax authorities.

  • assessing how existing finance processes and IT tools can be used to control transfer price settings. Should you consider changing your ERP system? We can contribute by developing with you the ERP design requirements for transfer pricing purposes and assessing whether an ERP solution or an add-on tool would best serve your automatization needs.

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