2016年-德勤全球_Trends_in_Transfer_Pricing_12页_1mb

Deloitte Transfer Pricing Trends Global Research Bulletin Summary

Core Content

Deloitte's 2016 global research bulletin highlights the evolving landscape of Transfer Pricing (TP) in the context of increasing regulatory scrutiny and the OECD's Base Erosion and Profit Sharing (BEPS) initiative. The report outlines key trends and challenges that multinational corporations (MNCs) are facing in managing their TP activities.

Main Trends and Views

1. Increased Control and Centralization

• Centralization is becoming a dominant trend, with companies aiming to enhance global consistency and process standardization.
• The goal is to minimize risk, improve efficiency, and reduce costs.
• Companies seek to balance central control with local input, recognizing the need for local knowledge and language skills.

2. Inconsistent Approaches and Dissatisfaction

• There is low satisfaction with current TP practices due to inconsistent internal approaches and difficulty in data collection.
• BEPS guidance has increased clarity about the future direction of TP, prompting businesses to re-evaluate their strategies.

3. Growing Resource Challenges

• Limited internal expertise and increased work volume are creating resource challenges.
• 98% of participants expect TP resource needs to grow or remain the same in the next 2–3 years.
• Specialization is becoming more critical as TP demands evolve.

4. Outsourcing as a Solution

• Outsourcing is expected to increase, especially for compliance and documentation.
• 98% of companies outsource to some extent, with reasons including changing regulations, lack of resources, and need for new expertise.
• Some companies use a mixed approach, combining in-house control with outsourcing for cost efficiency.

5. Technology-Enabled Solutions

• Technology adoption is seen as essential for improving efficiency and visibility in TP.
• Companies with better technology are more likely to report higher satisfaction.
• Digital DoX is highlighted as a Deloitte proprietary solution to automate data flows and enhance process efficiency.

Key Insights

• BEPS regulation is the primary driver of change in TP, influencing all other factors.
• Risk management is central to the TP strategy, with companies seeking consistency and control.
• Global coordination is increasing, but there is no single model for success.
• Technology is expected to play a larger role in TP processes, with a focus on automation and data management.

Summary of Survey Findings

• Compliance & Documentation is the area where most dissatisfaction is reported.
• Companies are rethinking their TP strategies in response to the global tax reset and increased regulatory demands.

Deloitte's Role

• Deloitte provides outsourcing solutions and technology tools to help MNCs manage their TP needs.
• It advises in-house departments on operational reevaluation and offers innovative solutions to support complex TP operations.

Conclusion

The Transfer Pricing landscape is rapidly changing due to globalization and regulatory developments. Companies are increasing control and centralization, while outsourcing and technology adoption are seen as key strategies to manage risk and improve efficiency. Deloitte emphasizes the importance of strategic rethinking and innovation in this evolving field.