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 2026

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

While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’
From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’
The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs
IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency
However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed
Gift this article