- 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
Group obligations mapped across jurisdictions before the first deadline
A group had grown into several countries without checking where documentation obligations had been triggered. We worked through each jurisdiction against its own rules rather than a regional assumption, and set out for each one what has to be prepared, what has to be filed, who the obligation falls on and when. The engagement produced a country-by-country compliance calendar sourced to each authority's own material, and a short list of the jurisdictions where the group was already inside the regime and had not realised it.
Contradictory local files reconciled to a single set of facts
Three subsidiaries had prepared documentation locally, and the same intercompany arrangement was described three different ways: different characterisation, different risk allocation, different rationale for the method. Because the authorities exchange the group's data, the inconsistency was the exposure rather than the pricing. We settled one description of the transaction centrally, then rebuilt each local file to present it in the form that country's rules require. The work produced a consistent set of files and a drafting standard the group now applies before any local file is signed.
First documentation set built for a newly acquired subsidiary
A group acquired a company in a jurisdiction it had not operated in before, and inherited intercompany flows with no documentation behind them. We identified the transactions, established what was actually supplied and which entity carried which risks, selected and justified a method on those facts, and built the file to the local content requirements. The engagement produced a documentation set for the first affected year, a description of each flow that the rest of the group could align to, and a note of what falls due in the following year.
Management charge defended during an administration's review
An administration questioned a recurring charge from the parent to a local subsidiary, on the basis that the benefit to the subsidiary had not been shown. We assembled what the charge actually covered, who performed the work and where, how the cost base was built and how it was allocated, and set that against the method used. The engagement produced a written defence file with the underlying evidence attached, and a revised charging note that records the benefit test when the charge is raised rather than years afterwards.
Commodity flow through a related trader documented end to end
A group moved goods through a related trading company in a third country, a pattern several jurisdictions single out for special treatment. We traced the chain from producer to final customer, established what the intermediary did and what it bore, and documented the pricing at each step against the rules of every country in the chain rather than only the two at the ends. The work produced a single narrative of the flow with a local file behind it in each jurisdiction, consistent on the facts and presented in each country's required form.
Intragroup financing reviewed against local documentation rules
A group funded several subsidiaries from a central entity and had treated the arrangements as internal housekeeping. Each country involved treats a related-party loan as a priced transaction that has to be supported. We set out the terms actually in place, the position of the borrower in each case, and what evidence each jurisdiction expects for the rate and the other terms. The engagement produced documentation for each loan, and a recommendation on which arrangements to paper properly before they were reviewed rather than after.
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 runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
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
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
