2013 Global Transfer Pricing Survey

Navigating the choppy waters of international tax

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Our 2013 Global Transfer Pricing Survey – an industry benchmark chronicling taxpayer views on this essential function of cross-border commerce for nearly 20 years – examines how companies are adjusting to new sources of controversy around the world.

This survey documents a clear shift toward prioritizing risk management in transfer pricing. The report identifies several sources of risk that may be contributing to this new, more cautious posture. These sources include the fact that more tax authorities say they view transfer pricing as a “high-risk” tax issue worthy of closer examination.

The growing willingness of tax administrations in rapid-growth markets to challenge transactions, as well as broad and intense focus by the news media and social justice organizations, have amplified the pressure.

And companies are well aware that the Organization for Economic Co-operation and Development’s (OECD) project on base erosion and profit shifting (BEPS) is likely to have substantial influence on transfer pricing rules. It should come as little surprise, then, that our new survey finds controversy and double taxation is on the rise.

Companies are struggling to manage a transfer pricing life cycle that has become more compressed than ever before. They are seeking to manage new players and new pressures in new places with fewer resources. And they are facing tax administrations that collect and share data like never before.

This report seeks to put these findings in the broader context of developments concerning cross-border taxation. We hope you find this comprehensive report to be useful.



Thomas Borstell
+49 211 9352 10601

John Hobster
+44 207 951 6438

Craig Viard
+1 312 879 6071

Loren Ponds
+49 211 9352 13157