In today’s rapidly changing transfer pricing landscape, having an effective approach to managing transfer pricing opportunities, compliance and risk has never been more important. The focus towards tax on value creation under the OECD’s globally accepted Base Erosion & Profit Shifting (BEPS) concept has given Multi-national Enterprise (MNE) groups a unique set of challenges along with increasing volumes and a variety of daily operational transactions.
Transfer Pricing is the pricing offered by one member of the MNE group to another member outside the country for exchange of goods, services, financial transactions and other intangibles. Cross-border intra-group transactions have become the norm. With these transactions, taxpayers must comply with the various enhanced and ever-increasing regulations across jurisdictions, which is time-consuming and complex. It can also leave businesses with inadequate time and resources for strategic and commercial decisions. With Automatic Exchange of Information (AEOI) and Country-by-Country Reporting (CbCR), tax authorities across the globe are sharing and can plan to share information in real-time on cross-border related party transactions through Multilateral Agreements.