- Countries covered
- 25
- Regions
- 6
- Sections per country
- 6
- Unverified figures
- None, anywhere in the guide
What this guide is, and what it refuses to be
Transfer pricing is the single tax question a multinational group cannot answer once and file away. The arm’s-length principle is close to universal, and almost nothing else is: the documentation a jurisdiction demands, the deadline it demands it by, the method it prefers, the consequence of getting it wrong and the appetite of its administration for an argument are all set nationally. A group operating in five countries has five positions to hold, and they have to be consistent with each other because the authorities exchange the group’s own data.
So this guide is organised the way the problem is: by country, each page written from that jurisdiction’s own rules rather than from a regional template. Each covers how the regime works, what documentation is required, how a price is tested, what we do about it, where audits actually concentrate, and who the obligation lands on at different sizes of business.
It also refuses to do the thing most country-by-country tax guides do, which is quote a threshold, a penalty or a filing date without saying where it came from. On these pages a section number, a rate, a currency amount or a day count appears only where it was read in the revenue authority’s own material or the country’s own legislation, and the page names that source and the date it was read. Everywhere else the mechanism is described and no number is given. A wrong figure in a transfer pricing file is not a typo — it is a position a client acts on and carries the penalty for.
Africa
Transfer pricing arrived comparatively late across much of the continent and has been arriving fast: documentation duties, related-party disclosure schedules and dedicated audit teams have all been added inside the last decade, and the authorities that run them are among the most active in the world relative to the size of their taxpayer base.
Asia Pacific
The region holds both the oldest and the newest regimes in this guide, and the widest spread of administrative style — from jurisdictions where an audit opens with a request for a value-chain analysis to ones where a single surcharge attaches automatically to any adjustment. Group structures that route through more than one of them rarely satisfy all of them with one file.
North America
Two of the three regimes here predate the OECD guidelines in their current form and neither defers to them entirely, so a North American file is usually written twice: once to the local standard and once to the standard the counterparty jurisdiction applies. Getting that pair to agree is most of the work on a cross-border engagement.
Europe
European transfer pricing looks harmonised from the outside — the same arm’s-length principle, the same three-tier documentation shape — and is not, because the documentation obligation, the production deadline and the audit posture are set nationally. A group with subsidiaries in five European states has five documentation calendars.
South America
The region has been moving toward the OECD model from its own starting point, which in several jurisdictions was a set of fixed-margin and commodity-pricing rules that owed nothing to comparables analysis. Where that shift is under way, the transition year is the year the documentation has to carry both stories.
Australia
Two mature regimes with unusually explicit reporting statutes and tax administrations that publish what they are looking at. That transparency cuts both ways: it tells you what an audit will ask for, and it means an unprepared file is unprepared against a published standard.
Where this connects to the rest of the practice
The guide is orientation for a group working out which jurisdictions it has an obligation in. The pages below are the work itself — the service, the fees, the surrounding cross-border questions a transfer pricing position raises, and the definitions behind the vocabulary used throughout.
What these engagements turn on
Whether Documentation Was Required At All
The obligation turns on the transactions that actually happened rather than on the size of the group, and the penalty for contemporaneous documentation is charged by reference to the adjustment. The review establishes which side of the line the company sits.
Read how this one runsA Pricing Study That Started With Who Does What
Functions, assets and risks decide which entity should earn the return, and the method follows from that rather than the other way round. Getting the sequence backwards is how a study fails on its first question.
Read how this one runsChoosing Between Methods on the Evidence
A comparable uncontrolled price is the strongest method where one genuinely exists, and reaching for it where it does not is weaker than a properly applied alternative. The choice is documented with the reasons for rejecting the others.
Read how this one runsDocumentation Built to the US Standard
The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.
Read how this one runsA Family Trust Abroad With Reporting on Both Sides
A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.
Read how this one runsAn Assignment Priced on an Equalisation Promise
A policy that leaves the assignee no better or worse off has to be computed, not just stated, and the hypothetical deduction runs alongside the real one. The engagement builds both and reconciles them at year end.
Read how this one runsA Taxable Presence Created Without an Office
A dependent agent habitually concluding contracts can create a permanent establishment where there is no premises at all. The review tests what the person actually does against what the treaty describes.
Read how this one runsWithheld at the Statutory Rate When a Treaty Rate Applied
Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
Non-Resident Canadian Tax
Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
