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Develop holistic approaches to business transformation, compliance, and controversy prevention and management worldwide

Global transfer pricing services
Network of local specialists with global reach Transfer pricing is a key component where business and tax intersect for multinational companies. Intercompany pricing remains a challenge in the ever-evolving legal and geopolitical landscape. Between local country and global tax reforms, escalating inconsistent and conflicting documentation and compliance requirements, strict penalties, and high-stakes audit activity, companies face elevated scrutiny over their transfer pricing policies.

PwC has over 5,500 specialists in over 150 countries, ready to support you with AI aided solutions around transfer pricing documentation, planning, and controversy & dispute resolution. Together, we can advise and develop compliant, industry-leading frameworks that drive your business objectives. Whether you are seeking guidance for effective corporate governance and internal controls for transfer pricing matters, defensible documentation on the allocation of system profit across the value chain and country borders, support through controversy, or analytics and automation for workflow management, our transfer pricing professionals are well positioned to advise you.

Explore our services PwC’s Global Coordinated Documentation™ (GCD) Public country-by-country reporting (pCbCR) Financial services transfer pricing Financial transactions transfer pricing TP controversy and dispute resolution Value chain analysis Operational transfer pricing (OTP) Value chain transformation PwC’s Global Coordinated Documentation™ (GCD) Today, your business faces demand for increased transparency and greater disclosure requirements. That means you’ll need an efficient, consistent framework for producing the documentation that defends your transfer pricing policy. You’ll need to know where to focus your efforts efficiently. And you’ll need to make sure you meet all requirements from local-country tax authorities, consistently among territories. PwC can help you tick all these boxes.

We can work with you to:

Analyse the potential implications of these requirements based on your global footprint and identify remedial actions to take before implementation, as well as establish a strategy for practical and efficient compliance.  Prepare the Master File and ‘core’ Local File using our GCD concept. This takes the ‘core’ document and uses it in each country as part of its Local File report, wherever you do business.  Analyse the output of your country-by-country report, including identifying how your business could address potential risks.  Review consistency of disclosures with the Master File, Local File and local information returns, as well as with other compliance items such as sustainability and public country-by-country related disclosures. Public country-by-country reporting (pCbCR) The integration of tax within sustainability increases as tax transparency becomes a significant part of  companies’ sustainability efforts. Companies’ tax contributions can positively impact local communities and environmental initiatives in territories where they operate, but this story is often not told or well understood.

With reporting requirements pending, the disclosure of pCbCR will be uncharted waters for most companies and is likely to represent the first time potentially sensitive country-level data on tax and profits will be made publicly available. The focus of pCbCR is on corporate income taxes, however new regulation gives businesses an opportunity and a foundation from which to tell their holistic tax story and help build trust with stakeholders.

Both the EU and Australia have introduced pCbCR reporting obligations. Find out more about pCbCR and how we can help:

EU public country-by-country reporting tracker Australia public country-by-country reporting 10 step plan to publish country-by-country reporting Financial services transfer pricing PwC’s financial services transfer pricing (FSTP) practice stands at the forefront of identifying and offering expertise on an extensive range of issues and developments within the financial services industry.

We can help you by:

Sharing insights and advice to address policy impacts of regulatory developments for financial services (FS) businesses, gained through our monitoring of the evolving regulatory landscape driven by organisations like the OECD, European Union, the UN, central banks and other stakeholders.  Providing pragmatic advice for sector-specific intercompany issues across FS sectors. Our guidance spans transfer pricing issues associated with cross-border real estate transactions; management company structures across traditional, alternative, or private equity Asset Management groups; proportional or treaty-based risk ceding transactions, and risk support or other services transactions for Insurance groups; and trading services, booking models, services, and other intercompany issues for Banking and Capital Market organisations.  Bringing sector expertise in the key service offerings provided by PwC including TP controversy and dispute resolution, GCD, and public country-by-country reporting. We link this expertise to the fast-changing environment facing FS clients today; helping clients navigate evolving value-chains and the rise of technology, sustainability and increased transparency.  View an engaging discussion with our PwC specialists on FSTP key trends in asset management.

Key trends in asset management Financial transactions transfer pricing Our  global and country-specific financial transactions transfer pricing (FTTP) network provides you with a depth of experience to deliver tailored, sustainable solutions in a dynamically changing global FTTP environment. 

Financial transactions are wide ranging, from straightforward loans to pricing of complex derivative products, cash pooling, factoring, as well as broader treasury operations (netting, hedging, foreign exchange management) and often can be material transactions within multinational groups. These transactions are central to funding across the multinational group and service liquidity provision, long term funding, and other operational and tax needs. Following revisions to the OECD Guidelines, greater scrutiny is placed on the economic substance of financial transactions, options realistically available to the counterparties, and ability/capacity to bear risk within entities of a multinational group. There has also been a shift in the way in which tax authorities have sought to analyse and challenge intercompany loans, guarantees, cash pooling and other financial transactions from a transfer pricing perspective. 

We can help you by providing support around the entire life cycle of intercompany treasury activity, including: 

Planning and consulting Pricing and policy setting Derivation of arm’s-length interest rates Debt-capacity and serviceability analysis Transaction support around key funding events  Locally compliant documentation Advance rulings Tax audit and dispute resolution Automation and technology TP controversy and dispute resolution Today, your business faces an ever-increasing risk of burdensome and complex TP controversy. In a world of increasing transparency, greater disclosure requirements, and an increasing trend of cross border information exchange, the risk of controversy and the need to effectively manage disputes has never been greater. In this environment, you need an end-to-end TP controversy partner that will support you in taking a proactive approach to preventing, managing, and resolving TP disputes, keeping you ahead of controversy and more in control of the challenges it can create for your business. 

At PwC, our TP controversy team is uniquely qualified to help you navigate disputes to faster resolution and better results. Offering a full range of controversy services along with collaborative technologies, we cover areas ranging from early risk identification and audit readiness to global dispute resolution. We are dedicated to keeping your company resolution-ready, resolving your TP controversies and delivering outcomes you can trust. 

We can work with you to: 

Develop controls, appropriate documentation and design processes to help you prevent controversy. We believe day-one readiness is your most effective defence against the spectrum of risk, mitigating its potential impact across your business, including reputational risk. Share insights to help you strategize for audits, leveraging decades of former Tax Authority and Competent Authority experience. When disputes are unavoidable, we believe in navigating those matters to faster resolution and better results. Support and manage double taxation via Mutual Agreement Procedures and litigation. Achieve greater certainty via Advanced Pricing Agreements. Consider the use of technology in your controversy function to help create bandwidth to think strategically and ensure consistency in response. Value chain analysis Transparency and sustainability demands on companies have escalated, especially with the recent developments surrounding public country-by-country reporting. Whether it is explaining the profit profile of your country-by-country reporting, evaluating the resilience of your transfer pricing generally, or testing the application of specific methods, it is much more important now to identify which activities in your business generate value and how profits get allocated, supported by empirical data and market realities.

Operational transfer pricing (OTP) The  world of transfer pricing is rapidly evolving. There is an ever-increasing wave of legislative and regulatory change, tax authorities are more sophisticated when it comes to data and systems and asking MNCs to “prove” the correct execution of their position in accordance with the transfer pricing policy, and in-house tax/transfer pricing teams are being asked to do “more with less” and get up the digital curve while being more closely aligned with the finance function. Amongst this change, there is a once in a generation shift with the introduction of ERP and Cloud based solutions which can more effectively digest, transform, calculate, and report data from core and non-core systems.    

PwC’s operational transfer pricing (OTP) team specializes to help clients harness the opportunities around more efficient and effective transfer pricing execution, ranging from data extraction and transformation, designing segmentation/allocation/calculation frameworks, to reviewing and modelling outcomes and production of outputs. Our approach is technology agnostic, and we work with clients to improve data, use technology as an enabler around an operating model that is focused on a target people, process, and governance framework.   

Solutions can range from being incorporated in a workstream of a larger organization-wide ERP migration or Finance Transformation initiative, to a transfer pricing focused project leveraging technology and approaches already existing within the organization. Whether a short sprint or large scale, multi-year integration, we tailor solutions to your organization’s goals.

Value chain transformation In today’s global business landscape, companies are continuously faced with increasing volatility and uncertainty. Coupled with a more challenging tax and trade environment, amplified by the impacts of Pillar Two as well as other trade-related geopolitical impacts, companies are having to navigate this uncertainty and headwinds on a real-time basis and with a forward-looking lens. From an end consumer perspective, expectations around service delivery, automation and AI also continue to escalate, putting pressure on companies to innovate at pace.  

Our value chain transformation services can help companies integrate aligned legal, governance and tax structures with business operating models to develop efficient and innovative strategies around trade, supply chain, and digitalization in a way that will create long-term enterprise value and address short term risk and costs. 

We can help you by: 

Providing insight on how other companies are handling the changing environment as well as strategies being implemented.  Listening to your business objectives and bringing an outside-in perspective.  Evaluating your value chain management process and finding a path to improvement.  Exploring value chain improvement options and co-developing the appropriate solution for your company.  Presenting tailored options that are aligned to your specific footprint and fact pattern Policy, Business, and Trade — Navigating Tomorrow’s Tax Landscape The global tax landscape is being reshaped by forces such as policy and regulatory change, digital transformation, and the rise of AI. Over 700 PwC and industry tax professionals recently gathered at PwC’s Global Transfer Pricing, Trade and Indirect Taxes Conference 2025 to discuss how these issues are shaping business strategy. Watch the videos (by clicking on the 'Learn more' button below) and tune into PwC's Policy on Demand for insight and analysis on how businesses can build resilient tax strategies amid today’s changing geopolitical landscape.

Learn more

Video 29/07/25 Asia-Pacific Transfer Pricing Roadshow: Mastering TP in 6:56 Closed captions settings Closed captions Off Font size Options Text color Options Position Options Font size Small Medium Large Extra Large Text color White Text Yellow Text Position Bottom Top More tools Closed captions Settings Transcript Off Back Back Back Full screen Off Share Closed captions settings Closed captions Off Font size Options Text color Options Position Options Font size Small Medium Large Extra Large Text color White Text Yellow Text Position Bottom Top

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Transcript Asia-Pacific Transfer Pricing Roadshow: Mastering TP in Dynamic APAC PwC’s Brian Burt and Andrew Fairfoull unpack what’s next for multinationals navigating tax complexity across APAC. From Pillar Two reforms and evolving tariffs to regulatory shifts in China, they explore how businesses can take a more strategic, long-term approach. The discussion spans tax-friendly hubs like Singapore and Hong Kong, and why companies should balance patience with bold moves when considering China decoupling or supply chain diversification.

They also dig into emerging value-based fee models in India, Indonesia and Malaysia, and how to build credibility with tax authorities through proactive measures like APAs. Throughout, they emphasize the power of a consistent global tax narrative — and why now is the time to lead with clarity, not react in silos.

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Ian Dykes

Global Transfer Pricing Network Leader, PwC United Kingdom

Tel: +44 7803 149718

Email Global transfer pricing contacts Get in touch Hide PwC office locations Site map Contact us © 2017 - 2026 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see http://pwc.zhutiblog.com/com/structure for further details. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.

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