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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