Advisory & Transaction Support

Transfer Pricing & Country-by-Country Reporting

Transfer Pricing & Country-by-Country Reporting

The international tax landscape has undergone radical change in recent years, spurred by the OECD’s base erosion and profit shifting (BEPS) project. A large majority of countries have implemented strict transfer pricing compliance, documentation and disclosure requirements and enhanced enforcement practices to target perceived corporate strategies that artificially shift profits to achieve tax advantages. ​

At Vistra, we can ensure your multinational enterprise complies with the transfer pricing documentation and disclosure requirements of all your countries of operation – this includes country-by-country reporting, master file and local file documentation. Our proven approach to assessing and documenting transfer pricing practices and giving recommendations has helped hundreds of multinationals across the world minimise their risks and promote tax efficiencies in a fully compliant manner. ​

Here’s a step-by-step summary of how we can help your organisation:​

Step 1: Assessment. We’ll review your countries of operation and their related transfer pricing requirements, including country-specific revenue thresholds and documentation requirements. ​

Step 2: Analysis. We provide an in-depth analysis of your related-party cross-border supply chain in light of the transfer pricing requirements of all your countries of operation.​

Step 3: Documentation. We’ll fulfil the transfer pricing documentation and reporting requirements of all your countries of operation based on our analysis – this includes country-by-country reporting, master file and local file documentation. ​

Stress testing and post-implementation review is another option if your transfer pricing documentation has already been prepared – we’ll work with you to understand your operational framework in light of your existing documentation. This may include, for example, revisiting your transfer pricing documentation for required updates due to local tax law changes or operational supply chain changes within your organisation.​

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