This report features a collection of articles from leading transfer pricing professionals at KPMG member firms. The report highlights the need for multinational companies to take a careful look at both tax authority guidance and their own current practices as they consider redrawing their transfer pricing policies in the new and different economic environment.

The articles deal with a variety of transfer pricing issues, including:

• The implications of the downturn and recovery for common intercompany structures
• The defense of transfer pricing arrangements in the recession
• The ability of taxpayers to mitigate issues with existing advance pricing arrangements.

The collective message is that many transfer pricing systems globally are facing unprecedented stress as the recession forces companies and revenue authorities to reassess their economic expectations. A longer-term and global perspective may be vital to helping achieve satisfactory results today and using change for lasting benefit beyond the current climate.