Global Transfer Pricing Services

Global Transfer Pricing Services

International businesses have to make sure all related party dealings are arranged at arm’s length.

Transfer Pricing is a major topic for international businesses.


Tax Transparency as asked for by a majority of countries is to be met by master-file and local-file documentation reports as well as by Country-by-Country Reporting (CbCR) disclosing key figures and information of the groups.

Value Creation

Ultimate allocation of taxable profits is with the creation of value, and hence diligent value chain analysis (VCA) are key to develop, manage and defend a company’s global profit attribution and tax set-up.


Only the translation of company’s business models into a sound transfer pricing policy allows for sustainable management and defense of the tax and transfer pricing set-up from day-to-day application to annual documentation.

Risk Management

Arm’s length conditions are in most cases ranges of discretion. What means companies must understand what the arm’s length standards are to assess and manage any thereto related risks.


KPMG’s Expertise

  • Key approaches and processes for development and application of master- and local-file reports, country-by-country reporting incl. SW tool assistance
  • Value Chain Analysis (VCA) methodology detecting and defining value creation activities, people and locations including DEMPE – Analysis for IP planning
  • Translation of business model and value chain realty into robust tax and transfer pricing policies, guidelines and manuals incl. contractual framework assistance
  • Tax and transfer pricing risk analysis for risk management and mitigation as well as reporting and provisioning including benchmarking as well as dispute resolution services


Further information

Response to BEPS Action 7 (PDF)

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Country-by-Country Reporting (CbCR)

Country-by-Country Reporting (CbCR)

KPMG's factsheet and offering toward CbCR, the new form of tax compliance for multinational groups.

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