United States

Common-sense Transfer Pricing Compliance in a BEPS World

Oct 17, 2017
From the KPMG TaxWatch

The need for comprehensive and consistent transfer pricing documentation has never been stronger

The Organisation for Economic Co-operation and Development base erosion and profit shifting (BEPS) project, combined with a sharper focus on intercompany fees and allocations by some nontax regulators, is causing multinational companies to reassess their compliance processes and resource requirements.

To navigate this increasingly onerous regulatory environment, multinational companies must take a common-sense approach. This requires having in place efficient processes to analyze, benchmark, document, and defend their related-party transactions. To that end, the following “rules of the road” are described in this article to guide companies in this regulatory environment. 

  • Rule #1: Know Your Transactions
  • Rule #2: Have a Policy in Place
  • Rule #3: Don’t Try to Fit a Square Peg into a Round Hole—Methodologically Speaking
  • Rule #4: Don't Assume Yesterday's Facts are Today's Facts
  • Rule #5: Transfer Pricing Isn't Just About Tax

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For more KPMG insights on BEPS, visit www.kpmg.com/us/beps.