Transfer Pricing at Year-End: Managing Cross-Border Tax Risks

Evaluate Transfer Pricing risks associated with cross-border intercompany transactions and assess whether pricing policies align with functional analysis, value creation and applicable OECD and local-country requirements.

Compare actual entity results with established Transfer Pricing policies and arm’s-length targets to determine whether year-end adjustments are needed and consider their timing and accounting treatment.

Analyze service charges, royalties, financing arrangements and other related-party transactions for consistency with intercompany policies and agreements, and identify applicable documentation and filing requirements.

Recognize related international tax considerations – including permanent establishment exposure, withholding taxes, customs, intercompany agreements and potential controversy or double taxation risks – and identify the cross-functional information needed for year-end calculations.