The impact of change management on TP from an industry perspective

Deloitte and ITR are pleased to announce the forthcoming ITR TP change management guide which will highlight the evolving unique changes across industries and sectors and related challenges and opportunities for multinationals in transfer pricing (TP).

The changes being highlighted are not limited to changes in value chains around digitalisation, but also impacts of mergers and acquisitions, booming private equity trends, consumer behaviours, supply chains disruptions, economic developments, regulatory changes and the end of LIBOR.

The following sectors and aspects will be highlighted in the ITR guide:

The article on technology, media and telecom introduces the so-called GOAL framework on how to recognise value created in the newly digitalised world as well as the importance of the framework of development, enhancement, maintenance, protection and exploitation (DEMPE).

The automotive sector is seeing some major shifts in the suppliers role not only limited to manufacturers and delivery of autoparts, but also product design, customer relationship management and are able to manage and control their relationships with the original equipment manufacturers (OEMs) besides the delivery of defect-free goods, while creating value as supply chain and procurement specialists, which is the key component in the article.

The consumer retail and wholesale distribution has been impacted by COVID-19 seeing significant changes in consumer behaviours and disruption in supply chains, as well as increased mergers and acquisitions (M&A) activities with value chain changes, impacting the current TP models, requiring more collaboration between business and tax departments that are heavily discussed in the article.

The article on transportation, hospitality and services emphasises how trust and loyalty will lift the most hurt sector during COVID-19 along with expected M&A and digitalisation.

The energy and resources article discusses how the industry is primarily impacted by structural changes and digitalisation which has challenged the TP aspects of ownership, management, use, and exploitation of intangible and high-value services, while the framework of DEMPE has become more significant in the TP analyses.

The article on industrial products and constructions assesses how the accelerating digitalisation changes business models of multinational enterprises in the industrial products and construction (IP&C) industry and elaborates traditional v. new digitalised business models along with guidance for how tax managers should review their TP in light of these changes.

The private equities article discusses changes and challenges in this growing sector around regulations, changes driven by customer demand and COVID-19.

The article on the end of LIBOR deepens the difference between LIBOR and other interest rates including the potential TP implications.

The fintech article describes how fintechs are changing the financial services industry and changing business models, while intangibles become more important, which were rather less significant in the traditional business models.

Click here to read Deloitte's TP Change Management in Industries guide

Jobst Wilmanns

Partner Deloitte Germany T: +49 69 7569 56243 E: jwilmanns@deloitte.de Jobst Wilmanns is a partner at Deloitte Germany, head of the firm’s TP service line in Germany and member of the Deloitte’s Global Transfer Pricing Steering Committee. Jobst is specialised in business model optimisation, TP execution and dispute resolution. He has extensive experience in advising a broad spectrum of multinational clients. He is also the global industry programme leader and EMEA industry leader. Jobst’s experience includes advising multinational companies mainly in the automotive, chemicals, pharmaceuticals, technology and engineering sectors.

Anodri Suchdeve

Senior manager Deloitte Germany T: +49 69 7569 57232 E: asuchdeve@deloitte.de Anodri Suchdeve is a senior manager at Deloitte in Frankfurt, Germany. Anodri started her career at Morgan Stanley and worked in the corporate tax department in New York, and financial control group in Frankfurt, primarily focused on controlling, TP, financial and regulatory reporting and thereafter the operational TP team in New York. After serving many years at Morgan Stanley, she joined Mitsubishi UFJ Financial Group in New York, and led the operational TP group as the Vice President while continuously streamlining operations, systems and especially alleviating and harmonising challenges between business units and related parties. Anodri advises a number of financial services clients on various TP matters, including operational TP topics.