Planning, Design and Implementation 

International transactions are playing an increasingly critical role as multinationals search for strategic advantage in today’s global markets. An important component of that advantage is a flexible transfer pricing strategy that balances opportunity and risk management, and weighs effective tax-rate reductions against tax authority challenges and the costs of compliance. An effective transfer pricing strategy must be global and sufficiently flexible to adapt as your business develops.

How KPMG can help

KPMG’s goal is to assist you in creating a transfer pricing strategy that is technically robust, based on solid economic theory, practical to implement, and adaptable as your business develops.

 A comprehensive transfer pricing strategy can:


  • Balance compliance, operational, and tax-efficiency needs.
  • Protect the past by providing economic justification for any changes from the existing transfer pricing policy.
  • Help reduce the implications for other taxes (e.g. customs duty, value-added, and trade taxes), and recognize and exploit new planning opportunities.

In helping to develop a transfer pricing strategy for your company, we can work with you to identify sustainable tax planning strategies that fit within your overall business strategy and may deliver significant, effective tax-rate benefits.

Examples of sustainable tax planning or Tax Efficient Supply Chain Management (TESCM) structures strategies include:


  • Intangible assets holding structures.
  • Contract or toll manufacturing structures.
  • Limited-risk distributor and commissionaire structures.
  • Cost-sharing structures.
  • Shared services centres.


KPMG’s GTPS practice brings together skilled economics, legal, finance, and taxation professionals who have extensive experience in transfer pricing and international taxation issues. The GTPS practice has a strong track record of pragmatic assistance and advice on developing and implementing transfer pricing strategies that deliver tax and risk management benefits.

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