How middle market companies can manage the transfer pricing life cycle

A transfer pricing guide for internationally active companies

Jun 14, 2022
Supply chain International tax Transfer pricing

Transfer pricing presents numerous challenges for internationally active middle market companies—especially for those exploring off-shore opportunities for the first time. With countries around the world adopting the guidance issued by the Organisation for Economic Co-operation and Development in relation to its base erosion and profit shifting (BEPS) initiative – arriving at a framework commonly referred to as BEPS 2.0 – in order to ensure value created in their markets is appropriately recognized and taxed, companies face an even tougher challenge and an even more rapidly evolving transfer pricing environment.

RSM’s guide Managing your transfer pricing life cycle walks middle market companies through guideposts of a successful transfer pricing program:

  1. Controlling risk and capitalizing on opportunity
  2. Gathering and translating your information
  3. Sustaining benefits through technology and an integrated process

From mapping your footprint to identifying your risks and opportunities, identifying and analyzing the right data to developing supportable economic analyses, this guide offers clear, practical insights, key questions, and considerations to address as you manage your transfer pricing life cycle such as:

  • Do your transfer pricing outcomes align to your transfer pricing outcomes and documentation?
  • Do you have clearly defined roles for the team responsible for managing your transfer pricing obligations?
  • Is your transfer pricing policy tax-efficient?
  • Have you determined which transactions have the greatest impact on your overall transfer pricing position?
  • Are your financial systems aligned to commercial, financial, and tax functions in addition to managing the business?

Transfer pricing is not a one-and-done activity. It should be a regularly monitored aspect of your tax planning and compliance risk management program. This concise guide offers executives a clear view of the challenges involved and an outline for addressing them.

RSM contributors

  • Tansy Jefferies

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