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Designing effective Transfer Pricing Policies

By Chad Martin
April 29, 2025
shipping container ship

Your transfer pricing policies are only as effective as the data that underpins them. Some struggles I see from tax function owners responsible for implanting TP policies:

  • Accounting differences between related buyers and sellers.
  • ERP system limitations.
  • Reliance on management financial statement results that don't track tax results.
  • Opaque and/or irreproducible processes (often intertwined with "key person risk").
  • Selective or ad-hoc adjustments to transfer pricing data.
  • Overly complex and administratively burdensome policy design.

The good news - Eide Bailly has the expertise to help mitigate these challenges. A few examples:

  • Stay in lockstep with local tax functions.
  • Beg, barter, or bribe your way into a seat at the table in ERP implementation discussions.
  • Always come back to the question "how does this tie to my tax returns?"
  • Document processes and (if possible) build in redundancy.
  • INSIST on practical support from the service provider who designed your transfer pricing policies.

Tax and transfer pricing can't and shouldn't happen in a vacuum. Buy your Financial Systems, Financial Planning & Analysis, and Accounting colleagues a coffee and spark that cross-functional flame.

 

Chad Martin directs Eide Bailly's Transfer Pricing Services practice.

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About the Author(s)

Chad Martin

Chad Martin

Principal, Transfer Pricing Services
Chad helps his clients navigate the complexities of today's global transfer pricing rules, regulations and opportunities. He helps companies structure and defend their intercompany transactions with an 'in-house' mindset.

Material discussed is meant to provide general information and it is not to be construed as specific investment, tax or legal advice. Keep in mind that current and historical facts may not be indicative of future results. This is meant for educational purposes only. Information presented should not be considered investment advice or a recommendation to take a particular course of action. Always consult with a financial professional regarding your personal situation before making any financial decisions.