Transfer pricing

Roles that need it

• Transfer Pricing Analyst
• Tax Associate
• Group Reporting Accountant
• Business Controller
• External Audit Associate

Skills it belongs to

• Intercompany transfer pricing
• Corporate taxation

Related concepts

• Permanent establishment (PE)A permanent establishment is a fixed place of business, or in some cases a dependent agent, through which a company carries on business in another country. The profits attributable to it can be taxed there, so branches and people working abroad need careful review.
• Double tax treaty (DTT)A double tax treaty is an agreement between two countries that allocates taxing rights on income such as business profits, dividends and interest, so the same income is not taxed twice. Most follow the OECD Model. In the EU, disputes under treaties can go to a binding resolution procedure.
• Pillar Two (global minimum tax)Pillar Two is the OECD and G20 global minimum tax of 15 percent on the profits of groups with consolidated revenue of at least EUR 750 million, measured jurisdiction by jurisdiction. The EU adopted it in Directive (EU) 2022/2523 with top-up taxes from 2024.
• Cost allocationCost allocation assigns shared costs, such as IT, operations or head office, to the products, business lines or entities that use them, using drivers like headcount, transaction volumes or usage. It feeds product profitability, pricing and internal charging.

Sources

• OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, OECD (external site) accessed 31 Oct 2026

Updated 31 Oct 2026.