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GLOBAL TRANSFER PRICING SERVICES

Planning for the Recovery
Examining Transfer Pricing in the Current Environment and Beyond
TAX

© 2009 KPMG International. KPMG International provides no client services and is a Swiss cooperative with which the independent member firms of the KPMG network are affiliated.

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Contents Introduction Stephen Blough and Clark Chandler Acknowledgements Steve Fortier, Sean Foley, Christian Looks and Steven Tseng Bringing Centralized Entrepreneur Structures Successfully Out of the Crisis Thomas Herr, Geoffrey Soh, Markus Wyss and Thomas Zollo Tango Lessons Marcelo Castillo, MartinGraña and Antonio Macias Transfer Pricing and the CPM/TNMM in a Downturn Clark Chandler and Moiz Shirazi Intercompany Services in Turbulent Times Jacek Bajger, Stephen Blough and Dirk Van Stappen Related-Party Loans Lucia Fedina, Burcin Kasapoglu, Damian Preshaw and Jaap Reyneveld Reacting to the Crisis – Can We Support Loss Splits? Cheng Chi, Gianni De Robertis, Atsuko Kamen and Hiroyuki TakahaskiRecessionary Business Restructurings Patricia Fouts, Tony Gorgas, John Neighbour and Stephanie Pantelidaki Advance Pricing Agreements Under Pressure Sean Foley and François Vincent Author Contact List 02 05

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© 2009 KPMG International. KPMG International is a Swiss cooperative. Member firms of the KPMG network of independent firms are affiliated withKPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

KPMG Planning for the Recovery

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Planning for the Recovery Introduction
The globaleconomic downturn has confronted transfer pricing practitioners with a host of challenges. A recession that began in the United States at the end of 2007 morphed into a severe global contraction following the financial crisis of September 2008.1 The International Monetary Fund (IMF) estimates that global GDP contracted at a 6 ¼ percent annual rate in the fourth quarter of 2008 and nearly as quickly inthe first quarter of 2009.2 While recent indications suggest that the pace of decline has slowed if not stopped, prospects for the end of 2009 and for 2010 remain very uncertain.

KPMG Planning for the Recovery

© 2009 KPMG International. KPMG International is a Swiss cooperative. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG Internationalprovides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

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Stephen Blough KPMG in the United States 2001 M Street, NW Washington, DC 20036 Phone: +1 202 533 3108 e-Mail: sblough@kpmg.comStephen Blough is a principal in the Economic and Valuation Services practice within KPMG LLP’s Washington National Tax practice. As one of KPMG’s senior economists, he manages transfer pricing engagements for some of KPMG’s largest clients and provides technical assistance on many other projects. Dr. Blough also directs the practice’s economic, statistical, and financial modeling services,...
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