Global Transfer Pricing – Is everything under your control? 

Transfer Pricing has become one of the hot topics for tax authorities all over the world and is also part of the daily business of international companies. However, we experience that there is still large potential for optimization among multinational in the area of transfer pricing that is not used adequately yet – which also holds for SMEs.

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Pressure from tax authorities increases risks


Transfer prices of international companies are in the spotlight of tax authorities world-wide. Thus, it has become more and more important to maintain a consistent and defendable transfer pricing system and to comply with the increasing documentation requirements. The remarkable tax risks in this area make it necessary to have reliable processes which ensure that companies are in line with regulations and simultaneously achieve tax efficient results.

As a company with cross-border intra-group transactions you need to know where you stand in the area of transfer pricing in order to develop, implement and defend an efficient transfer pricing system.


What are your challenges?

Our experience shows the following: tax authorities world-wide are more and more focusing on transfer prices in their tax audits accomplished by tightened regulations. Therefore, compliance and risk management should be of major importance also in your company.

Here are some typical questions and situations we often experience with our clients and that are also familiar to you:


  • Do you want to know exactly what are the chances and risks associated to transfer pricing in your company?
  • You have to adjust your transfer pricing system, because the underlying flow of goods has changed. 
  • Coming restructurings or changes in your business model need to be assessed from a transfer pricing perspective.
  • You want to ultimately solve your compliance matters (e.g. transfer pricing documentation)at a moderate cost level


How KPMG can support you


KPMG’s Transfer Pricing Team supports you with a pragmatic approach allowing for the discovery of potential issues before you are unpleasantly surprised. Our service offering with regard to all Transfer Pricing issues is tailored to your specific needs: 



status-quo-en implementation-en documentation-en risk-management-en


Status-Quo Analysis

  • We help international businesses to evaluate the status quo of their transfer pricing in order to identify potential tax risks and areas of improvement.



  • The best transfer pricing system is only worth as much as its implementation. Therefore, it is important to begin keeping an eye on the implementation side while developing the transfer pricing system for your group.



  • Comprehensive but too often one-off transfer pricing documentation reports that ask for huge recurring efforts are to costly and less and less supporting good compliance levels of international businesses. We offer a systematic approach including recurring documentation processes on corporate as well as on local levels.


Risk Management

  • Significant tax risks in any company may often derive from transfer pricing. Income adjustments and possible significant cash-outs related to additional tax payments can be limited or avoided.


Markus Wyss

Markus Wyss

Partner, Global Transfer Pricing Services

+41 58 249 41 29

Global Transfer Pricing Review

Transfer pricing is at the core of international trade within multinationals. This Review provides a wealth of local country transfer pricing information.

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Executive Program in Transfer Pricing (EPTP).


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