Transfer Pricing (TP) Deep Dives

Introduction Transfer pricing (TP) adjustments have become increasingly important for multinationals operating in Egypt, especially as the Egyptian Tax Authority (ETA) intensifies its scrutiny of related-party transactions. Differences between budgeted and actual margins, currency volatility, market fluctuations, and changes in supply chain structures often lead to profitability deviations from the arm’s-length range. A transfer pricing […]

Introduction In September 2022, the Organisation for Economic Co‑operation and Development (OECD) released significant updates to its Transfer Pricing Guidelines including new rules on financial transactions and intangible assets, a strengthened emphasis on economic substance, and refined guidance on hard-to-value intangibles (HTVIs). For multinationals based in Egypt or with operations in Egypt these changes carry

Introduction As multinational enterprises (MNEs) expand, shared services become essential for achieving efficiency, scalability, and operational integration. Functions like HR, IT, finance, procurement, strategic planning, and marketing are increasingly centralized to reduce cost and ensure consistency across regions. But with this centralization comes a major transfer pricing challenge: How should shared resources across borders be

Introduction Transfer Pricing (TP) in the manufacturing sector is uniquely complex. Manufacturers operate across multiple jurisdictions, manage global supply chains, engage in intercompany procurement, employ valuable intangibles, and often follow integrated production models. Because of this, transfer pricing is one of the most scrutinized areas during tax audits especially for companies with contract manufacturing, toll

Introduction Year-end transfer pricing (TP) adjustments are a critical compliance tool used by multinational enterprises (MNEs) to ensure their intercompany transactions align with the arm’s-length principle. Since actual financial performance often differs from projected margins, groups must assess and correct their transfer pricing results before closing the fiscal year. When performed correctly, year-end TP adjustments

Introduction Management fees and head office charges are some of the most common and most controversial intercompany transactions in multinational groups. Tax authorities across the world challenge these payments because they can be used (or perceived as being used) to shift profits between jurisdictions. To avoid disputes, adjustments, or penalties, multinational enterprises must justify, document,

Introduction Intangible assets such as trademarks, patents, software, technology, and know-how have become the most valuable drivers of profitability in multinational enterprises (MNEs). As a result, royalty transactions involving these intangibles are among the most heavily scrutinized areas in transfer pricing. Because intangibles are unique, difficult to value, and often transferred within related parties, tax

Introduction Transfer pricing rules around the world are built on a single foundation: the arm’s-length principle. To determine whether related-party transactions comply with this principle, tax authorities rely heavily on Functional and Risk Analysis (FAR). A robust FAR analysis is the backbone of defensible TP documentation without it, even the most sophisticated benchmarking or economic

Introduction Transfer pricing is one of the most scrutinized areas in international taxation. As multinational companies increasingly engage in cross-border transactions such as services, goods, financing, and IP transfers tax authorities expect these transactions to follow the arm’s-length principle. Choosing the right transfer pricing method is critical for ensuring compliance, avoiding disputes, and reducing tax