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

Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
The expansion introduces ‘business-level digital capabilities’ for tax professionals, the US tax agency said
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
Partners want to join Ryan because it’s a disruptor firm, truly global and less bureaucratic, Tom Shave told ITR
If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate
Gift this article