Beyond the Pandemic: Global Transfer Pricing Trends Drive Change

It’s no secret that the world is changing at an accelerated rate. The world of transfer pricing is no exception. The practice will – like everything else in these unprecedented times – have to adapt.

Mason Rak has spoken with transfer pricing leaders across the globe, who expect great changes in the world of TP to be accelerated as a result of the upheaval of the novel coronavirus and the resulting economic disturbances across the world.

The virus has, for now, made issues other than TP reform shoot to the top of jurisdictions’ to-do lists: witness the US’s spectacular exit from the OECD’s digital taxation negotiations in June. However, sooner or later the same trends that preoccupied tax authorities and professionals will come creeping back onto the agenda. Thus, with the USA and the global digital tax work: Pascal Saint-Amans, the head of the OECD’s Centre for Tax Policy and Administration, quietly said a few days ago that he expects the USA to return to the table once its contentious election season is over.

In other words, seismic change to the architecture of the global transfer pricing system is still on the way. In the last few months we have witnessed transfer pricing professionals leveraging their expertise to capitalise on TP market prospects for upside career potential, making change work for them rather than always reacting to the latest developments.

What does proactive TP management mean in a context of global uncertainty? One example would be thinking about how the European Union’s Digital Services Tax – now raised from the dead and due to be introduced in 2021 – certainly will provide opportunities for TP optimisation rather than just another compliance headache. Top tax academic Christine Kim points out that, because the DST is supposed to be levied on gross turnover, it functionally reduces the profit margins of the EU parts of a group, opening the possibility of tax optimization by moving substance to the right location.

What at first appears to be a compliance challenge can be transformed into an opportunity by the right team with the right skillset. This fact grows in importance when the numerous unilateral changes with TP implications that we have begun to experience in recent years – the UK’s own digital services tax being a prime example – are brought into view. As one senior TP leader put it to us: “The more changes that countries make, that will drive planning in the space. Where there is planning, TP [teams are] along for the ride on that, and more often in the driving seat.”

In executing strategic TP assignments across different global regions, we have observed how proactive TP management also means an ability to understand how the financial conditions created by the pandemic will differently affect the actions of governments in different regions. Tax authorities in East Asian countries with a better grip on the pandemic are likely to show less patience with corporations, for example, than authorities in jurisdictions where the economic fallout from the pandemic continues to be severe.

Some cash-strapped tax authorities may be more predisposed to settle disputes rather than let them drag on. In some cases, like in Brazil, this more dovish stance is attached to a commitment to multilateral change through the adoption of OECD standards.

In the Middle East, meanwhile, analysts at Mason Rak anticipate that the financial pressures of the global economic picture will add further volatility to what is already a fast-changing TP landscape. In the last two years, countries in the region have issued a spate of TP legislation where previously guidance (and disputation) was thin on the ground. Based on our knowledge in the region, an uptick in audit activity and disputes is not a ‘wait-and-see’, but an ‘it’s-happening-already’, accelerated by the fallout from COVID-19. Proactive TP managers foresaw the changes and were ready for them. Other companies will need to quickly onboard personnel to build their TP capacity in the region.

In recent years, there have been increased discussions regarding ‘operational transfer pricing’, a concept that allows companies to monitor and proactively respond to changing transfer pricing landscapes in order to solve problems nimbly and enhance process management through technology.

Yet in our experience, it probably remains true that the best way to face the global TP future is not by reinventing the wheel but by strengthening existing teams and enhancing tools at their disposal. Especially in an era of remote working, communication skills and a proven ability to build confidence and inspire teams will be crucial. In a business environment where companies in all jurisdictions are looking for savings, building trust is harder than ever, according to a TP head at a leading professional services organization. 

As the partner promotion track narrows in the big four firms, we anticipate some TP talent will be looking for ways to continue advancing in their careers, giving a big opportunity to ambitious law firms and smaller boutique advisory firms, as well as to multinationals looking for TP leaders who already have all the skills to bring value from the first day.

The truth is that the ideal TP hire doesn’t just bring subject-matter expertise or skills in building and maintaining relationships to the table. The ideal hire brings both.

Mason Rak is a global specialist tax and transfers pricing search firm, who operates extensively across all key global markets. The firm executes some of the most challenging strategic TP assignments and acts as a trusted advisor to accountancy and law firms around the world. If you would like to learn more about the global market and strategic transfer pricing opportunities, please contact Oleg Rak, Managing Partner, on [email protected] or call +44 786911 3281.  




    United States

    Successfully identified the following individuals for global professional accountancy and law firms in New York, San Francisco (Silicon Valley), Chicago, Dallas and Houston:

    • Head of International Tax
    • Transfer Pricing Partner
    • International Tax Partner
    • Transaction Tax Partner
    • Transfer Pricing Director
    • Head of Transfer Pricing (Law Firm)
    • Transfer Pricing Partner
    • Transaction Tax Partner


    Successfully placed the following roles within leading professional accountancy and law firms:

    • Transfer Pricing Partner
    • Indirect Tax Partner 
    • Transfer Pricing Partner 
    • Transaction Tax Director 
    • Tax Disputes Director
    • Tax Legal Director


    Mandated to strategically growth Tax business for several international and domestic  professional services and law firms in Munich, Frankfurt and Dusseldorf:

    • Expatriate Tax Director
    • Transfer Pricing Partner
    • Real Estate Tax Senior Manager
    • Transfer Pricing Manager 
    • Transaction Tax Director 
    • Transfer Pricing Director
    • Transfer Pricing Team Move 
    • Indirect Tax Partner 


    Over 25 mandates completed for professional services and law firms  including:

    • Head of Transfer Pricing 
    • Financial Services Tax Director 
    • International Tax Partner (Law Firm)
    • M&A Tax Senior Manager 
    • International Tax Director
    • Indirect Tax Partner
    • Tax Legal Partner

    United Arab Emirates

    Engaged on a transformation search project to identify the Tax Leadership team for the  professional services tax team across the UAE market:

    • Head of Tax
    • Head of Transfer Pricing
    • and Head of Indirect Tax
    • Expatriate Tax Director 
    • Head of Financial Services Tax major international professional services firm in Abu Dhabi

    Hong Kong

    Successfully identified an International Tax Director and Financial Services TP Head for leading professional services firms.