As shown by the recent works at G20, OECD, European or UN level, multinational enterprises (MNEs) have to adapt to rapidly changing legal and economic environments:
- legislations and practices evolve constantly and become more complex, and dealing with them in a cross-border context is a significant challenge
- with local and global regulations becoming more prescriptive, the number and complexity of tax investigations being conducted by specialised teams within local tax authorities is rapidly escalating, and the quantum of tax adjustments is rising accordingly
Within this framework, the design and implementation of internal pricing represents much more than a compliance issue. Clear and practical advice is critical to the establishment of a robust, tax effective structure; transfer pricing is providing significant opportunities for MNEs to adapt internal remuneration policies to maximise tax effectiveness and ensure close alignment with business and commercial strategies.