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Transfer Pricing

Increasing efficiency in value creation

Transfer pricing is an effective tax planning tool for multinational company groups. For this reason, transfer pricing plays an important role in international discussions on tax planning.

Many transfer pricing approaches are currently being questioned and redefined. In this rapidly changing environment, PwC provides support through its international team of experts – from design and implementation of transfer pricing through to documentation and compliance.

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How we can provide support

Intra-group transactions are becoming increasingly complex. In addition to the digitisation and integration of business models, compliance requirements are increasing. These developments make a needs-oriented approach to intercompany transfer pricing more important than ever.

Our interdisciplinary team and global network support you in identifying a strategy and designing your transfer pricing system, as well as helping you to implement and monitor the system using technology. We take account of your business needs and requirements and build on existing potentials.

As part of the BEPS project, the OECD has defined new documentation standards. Accordingly, group companies need to prepare master files, local files, and country-by-country reports. The scope of documentation has thus significantly increased on the level of both content and detail. The required content, deadlines, and penalties are country-specific.

We rely on our global network and implement documentation tools developed in-house to support you in analysing existing documentation and setting up newly required documentation. Benchmarking analyses for transactions and profit margins, as well as in-depth analysis of the value chain are used.

The international discussion around BEPS and tax avoidance has increased in intensity. The number of audits focused on transfer pricing has also increased. We support you to implement transfer pricing systems during tax audits and appeals procedures, as well as – to avoid international double taxation – in mutual agreement and arbitration procedures.

Companies in many countries can reach agreements with the tax authorities relating to transfer pricing to establish legal certainty in advance. We use our technical experience, and that of the international PwC network, to conclude agreements of this kind in your interest.

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Oliver Kost

Oliver Kost

Partner, PwC Austria

Tel: +43 1 501 88-3305

Marianna Dozsa

Marianna Dozsa

Partner, PwC Austria

Tel: +43 1 501 88-3239