New Zealand


  • Service: Tax, Transfer Pricing Services
  • Type: Business and industry issue
  • Date: 15/04/2011


Kim Jarrett

Partner - Tax

+64 9 363 3532


Managing transfer pricing implications of complex supply chains 

Transfer pricing around corporate supply chains has become increasingly complex and closely scrutinized in recent years. This new publication from KPMG’s Global Transfer Pricing Services focuses on three discrete types of supply chain issues.
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Part one discusses the implications of the new Organisation for Economic Co-operation and Development (OECD) Guidelines on Business Restructuring.


This section includes specific country perspectives on business restructuring concepts from: Australia, Belgium, Canada, China, Denmark, France, Germany, Italy, Japan, the Netherlands, Spain, the United States and the United Kingdom.

The second part focuses on a few selected issues that arise in many multinational enterprise’s (MNEs) supply chains.

The last section of this publication discusses controversy, including a discussion of two new tools to help taxpayers resolve controversy—accelerated competent authority procedures (ACAP) and binding arbitration—as well as a discussion on navigating transfer pricing controversy in India.


The section looks at the rapid growth of advance pricing agreements (APAs) in Asia and includes APA- statistics in Australia, China, Japan and Korea.


Finally, it includes a discussion of two court cases that have significant implications for supply chain management and restructuring—the General Electric case in Canada and the Veritas case in the United States.