Transfer Pricing Documentation Strategy

How PwC can help

Success factors for future transfer pricing documentation will require a shift from compliance to strategic risk management. With the drive for transparency, a need for consistency across all jurisdictions in respect to the TP documentation is in the spotlight.


As multinationals globalise, and countries adopt stricter rules for transfer pricing, the compliance requirements associated with transfer pricing reporting and documentation have increased. Think about the OECD action plan on base erosion and profit shifting that aims at implementing a new three tiered approach on transfer pricing documentation.

In addition, the Luxembourg government implemented general transfer pricing legislation and the Luxembourg tax authorities have further increased their focus towards transfer pricing. We have been following and monitoring these evolutions very closely. We can assist you in developing new transfer pricing policies and performing risk reviews on your current transfer pricing policies and subsequently documenting those policies in line with local and OECD Organisation for Economic Co-operation and Development requirements.

Transfer pricing advice and subsequent documentation will often involve more than one country. There we apply PwC’s Global Coordinated Documentation™ system that offers a streamlined alternative that helps multinationals deal with the requirements of multiple jurisdictions in an efficient and coordinated manner.


While transfer pricing compliance is principally a matter for senior tax executives, responsibility for the actual execution of inter-company transactions is generally spread out across a broad chain of often detached internal functions and distant offices.

The entire process typically involves multiple hand-offs between tax, regional/global controllership, shared services, information technology, and external advisers. In the absence of unified oversight or co-ordination, fiscally unsound conditions can develop at every transaction point.

We can help you reinvent your E2E (End-to-End) strategy and processes, leading to a more streamlined approach, reduction in workload, increased accuracy of charges, significantly enhanced transparency, and - not least - well-positioned documentation to support future reviews, including local statutory audits.

Our team of transfer pricing professionals can help you:

  • Transfer Pricing strategy and policy
  • Three-tiered approach, i.e. Master File, Locale File, and Country-by-Country Report ("CbCR")

  • Technology solutions for Transfer Pricing Documentation 

  • Functional Analysis

  • Benchmarking studies

  • Substance and Governance

  • Controlled Foreign Corporation ("CFC") 

  • Permanent Establishment ("PE") 

  • Global Coordination with PwC Network, i.e. 3,000 transfer pricing professionals deployed in more than 90 countries


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