Changing times: transfer pricing issues in the oil and gas industry

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Changing times: transfer pricing issues in the oil and gas industry

By Randell G. (Randy) Price and John M. Wells, national transfer pricing leaders – Deloitte oil and gas industry

On behalf of our Deloitte Touche Tohmatsu Limited tax colleagues who focus on transfer pricing issues within the oil and gas (O&G) industry, we are pleased to present this collection of papers on industry developments and issues.

The O&G industry's global transfer pricing landscape is in a state of change. From a macroeconomic perspective, oil prices have fallen by approximately $45/barrel over the last year, active drilling rig count is near a five-year low, thousands of industry jobs have been lost, and the capital budgets of E&P companies have scaled back significantly.

With that list as a challenging backdrop, the O&G industry (as well as the global tax community) was greeted with what may be considered the most comprehensive changes to the transfer pricing framework in nearly two decades as the G20 and the OECD issued proposed new transfer pricing guidelines under the base erosion and profit shifting (BEPS) initiative. The BEPS documentation guidance fundamentally changes transfer pricing considerations for the globally-reaching O&G community and ushers in a new paradigm regarding transparency. In addition, the BEPS Action Plan states that key changes may be needed in how companies approach the valuation of intangibles, price risk allocations, and acknowledge or respect intercompany agreements.

Our approach to this guide is to bring some order to this change. Therefore, we begin with a primer on transfer pricing challenges posed to the O&G industry by the BEPS transfer pricing deliverables. Next, we turn our attention to transfer pricing challenges given the current (and potentially protracted) economic downturn. Two articles focus on specific industries that are facing challenging environments due to commodity price deterioration: (i) transfer pricing issues in the contract drilling sector; and (ii) transfer pricing issues in the liquefied natural gas (LNG) space. The final industry article addresses the challenges and opportunities for the O&G industry regarding intellectual property migration. We have also included an overview of recent transfer pricing developments for Australia and the UK, because they appear to be at the forefront of BEPS-responsive initiatives.

More information on transfer pricing issues in specific countries and Deloitte Tax contacts locally are contained in Deloitte's Global Transfer Pricing Desktop Reference (www.deloitte.com/tax/strategymatrix). We hope you find our publication interesting and, more importantly, of practical use, and we invite you to contact our leading team of professionals if you have any questions.

more across site & shared bottom lb ros

More from across our site

In his newly created role, current SSA commissioner Bisignano will oversee all day-to-day IRS operations; in other news, Ryan has made its second acquisition in two weeks
In the age of borderless commerce, money flows faster than regulation. While digital platforms cross oceans in milliseconds, tax authorities often lag. Indonesia has decided it can wait no longer
The tariffs are disrupting global supply chains and creating a lot of uncertainty, tax expert Miguel Medeiros told ITR’s European Transfer Pricing Forum
Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award
Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds
Veteran Elizabeth Arrendale will lead the new advisory practice, which will support clients with M&A tax structuring, post-deal integration, and more
MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit
Nobody likes paperwork or paying money, but the assertion that legal accreditation doesn’t offer value to firms and clients alike is false
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
SKAT, which was represented by Pinsent Masons, had accused Sanjay Shah and other defendants of fraudulent dividend tax refund claims
Gift this article