Transfer pricing
Fast-moving changes and significant regulatory developments
Managing risk in the global economy
In the ever-evolving legal and geopolitical landscape, Transfer Pricing (TP) is an important element where business and tax intersect for multinational companies. With more than 5,500 professionals in over 150 countries, PwC's transfer pricing network of teams is well-positioned to support you with AI aided solutions around transfer pricing documentation, planning, and controversy & dispute resolution that can help advance your goals and navigate your complexities within the ever-challenging global landscape.
An increasing focus on transparency
Managing transfer pricing risk remains critical in an increasingly targeted, transparent business environment, and as the Base Erosion and Profit Shifting (BEPS) debate leads to greater international tax regulation and review.
Amidst sweeping global tax reforms, increasingly fragmented compliance obligations, and intensifying regulatory scrutiny, transfer pricing has transcended its traditional role as a technical requirement to become a strategic imperative. Businesses operating across borders must now proactively evaluate their risk exposure and adopt future-ready, business-aligned transfer pricing frameworks that are both operationally efficient and rigorously governed.
Hong Kong occupies a distinguished position as a nexus of international commerce and a super-friendly hub within the global tax ecosystem. Its expansive and resilient tax treaty network reinforces its role as a trusted jurisdiction for cross-border cooperation and dispute resolution. The Inland Revenue Department (IRD) of Hong Kong has notably escalated its enforcement of transfer pricing regulations, driven by bilateral considerations and mounting pressure from competent authorities worldwide.
In this dynamic regulatory climate, clarity is no longer a luxury—it is a necessity. Organisations must move beyond reactive, siloed approaches and embrace a consistent global tax narrative. This entails the adoption of coherent, internationally harmonised dispute resolution strategies, including Advance Pricing Arrangements (APAs) and Mutual Agreement Procedures (MAPs), which are increasingly championed by the IRD as proactive instruments to establish credibility and mitigate controversy.
Whether your organisation seeks strategic guidance on corporate governance and internal control frameworks, comprehensive yet cost-effective documentation across jurisdictions and value chains, expert navigation through controversy and cross-border disputes, or advanced analytics and automation to optimise data workflows—our team delivers the capabilities, local insight, and global reach to keep you ahead of the curve.
With deep regulatory acumen and a nuanced understanding of Hong Kong's evolving tax landscape, we are your trusted partner in managing transfer pricing risk with precision, foresight, and confidence.
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