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Transfer Pricing 

Helping you plan now for future transactions


As more goods and services flow between countries, governments eager to defend their respective tax base have imposed strict and complex transfer pricing regulations and stiff penalties for non-compliance.

Transfer Pricing

What is transfer pricing?

Transfer pricing is the price at which products and services are transferred between international subsidiaries and similar entities.

 

Plan for the future

Tax executives should plan for the future and address transfer pricing issues long before any transactions occur.

 

A global approach to transfer pricing

To meet the requirements of widely varying local rules and model rules set out by the OECD, your multinational business should consider an effective global approach to transfer pricing that encompasses arm's-length pricing, not just for tangible goods, but also for services and transfers of intangible assets, group financing, and other key areas.

 

Some businesses also turn their transfer pricing policies into strategic tools for investment and supply chain decisions, as well as for global tax planning.

 

Meeting these challenges

The economists, tax practitioners, lawyers, and financial analysts of our Transfer Pricing Services practice take a broad view and look beyond the present to help you establish policies to that can make your transfer pricing commercially viable and tax-efficient.

 

Our Transfer Pricing practice operates in every region of the world to assist with your transfer pricing needs wherever your company does business.

 

A multidisciplinary approach takes into account all aspects of Transfer Pricing.

 

Planning - Does your company have commercially sensible and fiscally viable transfer pricing policies? It's important to work with a firm that understands them and can help you develop and later modify them as new rules or circumstances require.

 

Compliance and Documentation - To comply with local fiscal requirements, you should design transfer pricing policies and procedures, and prepare documentation for a strong first-line of defence against fiscal authority audits. You can do this with KPMG's Interpreter®, our advanced, Web-based transfer pricing technology.

 

Dispute Resolution - When tax disputes arise, it's important to plan a strong, detailed response backed by economic and legal justifications for your existing prices. It's also very helpful to have assistance from qualified and experienced Transfer Pricing professionals in your dealings with fiscal authorities to look for avenues and options tailored to your needs.

 

Alternative Dispute Resolution - Have you assessed the risk of fiscal authority challenges? Do you know how to reduce and manage transfer pricing risk factors? Our Transfer Pricing professionals can assist you with Advance Pricing Agreements (APAs) or Competent Authority and Accelerated Competent Authority Procedure (ACAP) claims and negotiations.

 

Please contact us to find out more about how we can help you.

 

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 Contact

David L. Francescucci

David L. Francescucci

Partner, National Leader, Transfer Pricing

514-840-2395

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Related Links

KPMG Law

KPMG’s affiliated law firm, KPMG Law LLP, provides a suite of wide-ranging tax and immigration law services.

Navigating APAs

KPMG’s Navigating APAs report consists of in-depth interviews with tax directors from 25 multinational companies in seven countries. The findings of this report were reviewed and analyzed by a panel of Transfer Pricing Leaders from a number of KPMG member firms.


For more information on this report, please contact:

 

Toronto

Michael Glaser
Partner, National Leader, Canada, Global Transfer Pricing Services
604-691-3165
mglaser@kpmg.ca

 

Jim Gatley
Partner, Transfer Pricing
416-228-7091
jgatley@kpmg.ca

 

Montreal

Joelle Hall
Partner, Tax
613-212-3779
jshall@kpmg.ca

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