Driven by ever-advancing technologies, today's
multinationals need to quickly adapt to new ways of doing business
— a process that can often leave them more vulnerable to risk
including tax and transfer pricing, especially since new
legislation and rules have been introduced post Base Erosion and
Profit Shifting ("BEPS") project outcomes. Adequate and
supportable transfer pricing model implementation can be a
challenge for those who hope to withstand heightened scrutiny.
Take a manufacturing business. In the past, when brick and
mortar factories still ruled the day, value created along the
supply chain was easier to identify and therefore, where profit
should arise and be taxable. With the rise of 3D printing and IP
becoming one of the core drivers of the business, for example, that
value chain has been altered, mostly centering around software,
know-how and the key R&D people who develop the IP.
