Compliance and Documentation 

Although the transfer pricing guidelines developed by the Organization for Economic Co-operation and Development (OECD) form the cornerstone of local legislative requirements in many countries, companies must comply with the variants of local legislation in the countries in which they operate. Local tax authorities are increasing their efforts to examine transfer pricing issues more closely and to strengthen requirements through local legislation, including documentation requirements.

This places a substantial compliance burden on multinationals and increases the risks of penalties and costly transfer pricing inquiries. Companies need to be sure they comply with local tax requirements and that they have a system in place to ensure future compliance.

How KPMG can Help

Our GTPS professionals can advise you on local legislative requirements and review your existing policies to help you determine whether they are compliant. We can help create a transfer pricing policy that complies with local legislation and is supported by a robust analysis.

Compliance has its price. Our aim is to advise your company on policies and procedures that both meet your business and tax requirements and help reduce administrative costs.


Documentation: first impressions are critical
The scope of any transfer pricing inquiry by tax authorities will be influenced by a company’s ability to present contemporaneous documentation of the arm’s-length nature of its transfer prices and by the quality of such documentation. First impressions are critical if you are to limit the scope of an inquiry.

Many multinational companies have basic documentation available, such as pricing policies, product profitability, and market information. These alone, however, will not be sufficient in most cases to satisfy the local transfer pricing documentation requirements.


KPMG can assist you in complying with local documentation requirements and in establishing a credible line of defense.  We can help you prepare such documentation or we can review existing documentation for completeness.


Our GTPS professionals are familiar with the approaches local tax authorities typically use in reviewing transfer pricing documentation. We leverage this knowledge when working with you to determine the right approach for your circumstances and your perception of the risks involved. Interpreter™, KPMG’s proprietary transfer pricing software, provides a platform for the efficient collection and analysis of information about your company.  Please access the Interpreter web page for more information.

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