Companies operating across borders are the engines of global commerce.However, operating across multiple jurisdictions with different fiscal requirements places a burden on multinationals as they seek the most efficient locations for their investments. Transfer pricing is the traditional avenue to ensure that each entity pays the requisite tax in the jurisdictions it operates.
In the recent past, there have been concerns that traditional transfer pricing documentation requirements do not provide revenue authorities with adequate information to assess cross border operations resulting in the Organisation for Economic Co-operation and Development (OECD's) Base Erosion and Profit Shifting (BEPS) action plan. It is now imperative for multinationals to present globally consistent arguments supporting their transfer pricing decisions, substantiated by thorough, authoritative analyses that reflects local rules governing their transactions.
Added to the increased call for greater transparency and morality in business decision making, multinationals are left facing more complexity than ever before.