Global trade tensions and supply chain challenges: transfer pricing considerations for 2025

This article provides a comprehensive analysis of how tariffs are reshaping transfer pricing strategies. It explores the implications of ad valorem, specific, and compound tariffs on intercompany pricing and supply chains.

Deloitte Germany’s experts offer strategic options for multinational enterprises (MNEs) to adapt their models, including supply chain restructuring, contract renegotiations, and leveraging free trade agreements. The article emphasises the importance of price elasticity, documentation, and proactive planning to maintain compliance and competitiveness in a volatile trade environment.

Amid ongoing Europe–US trade frictions, the automotive sector faces mounting pressure to rethink its transfer pricing structures. Deloitte Germany’s specialists examine the impact of reciprocal tariffs on European and Asian manufacturers, and outline short- and long-term strategies for MNEs. These include adjusting transfer prices, restructuring supply chains, and evaluating price elasticity to mitigate margin compression and compliance risks.

The article uses illustrative examples to demonstrate how MNEs can preserve arm’s-length margins and adapt to evolving trade policies.

Life sciences and healthcare companies are increasingly affected by changing tax incentives, trade barriers, and evolving transfer pricing regulations. Deloitte Germany’s experts assess how global value chains in this sector are responding to OECD pillar two rules, grants, and disincentives such as the US Base Erosion and Anti-Abuse Tax (BEAT) regime.

The article explores the implications for transfer pricing documentation, policy design, and the treatment of R&D incentives. It highlights the importance of unbundling transactions, localising value-adding activities, and monitoring regulatory developments to ensure compliance and optimise tax outcomes.

With inflation, supply chain shocks, and trade tensions challenging legacy transfer pricing models, Deloitte Central Europe’s specialists propose a framework for evaluating the robustness of economic analyses.

The article discusses alternative methods such as the return-on-assets-based transactional net margin, profit splits, and comparable uncontrolled prices, and emphasises the need for more resilient and adaptive transfer pricing strategies. It also addresses the limitations of outdated comparable data and the importance of revisiting assumptions and input sources to maintain defensibility.

Deloitte China’s experts provide practical insights into the feasibility and implementation of year-end transfer pricing adjustments in China. The article discusses inbound and outbound adjustments, foreign exchange considerations, and recent regulatory developments, including Shenzhen’s new guidance. It outlines the challenges posed by customs certificate requirements, local practice variations, and potential VAT implications.

The article offers recommendations for managing transfer pricing assessments through proactive planning, documentation, and engagement with banks and tax authorities.

Deloitte Spain’s specialists examine how tax authorities are increasingly scrutinising risk allocation within MNE value chains.

The article outlines the OECD’s six-step risk framework and highlights common audit challenges, such as misinterpretation of local expenses and contractual clauses. It provides recommendations for managing tax risk, including conducting proactive risk analyses, aligning transfer pricing policies with functional characterisations, and implementing internal protocols to mitigate controversy.

Deloitte Germany’s experts analyse how financial market volatility, foreign exchange fluctuations, and interest rate changes are affecting investment, financing, and supply chain decisions. The article explores the transfer pricing consequences of intragroup financing arrangements, including loans, cash pooling, and guarantees. It discusses the impact of market uncertainty on functional and risk profiles, documentation requirements, and the need for flexible pricing models.

The article also highlights the importance of risk management and the role of treasury functions in navigating volatile environments.

As generative AI (GenAI) and cybersecurity reshape global value chains, Deloitte Germany’s specialists explore the transfer pricing challenges of digital services.

The article discusses governance, data valuation, and the treatment of intangible assets, offering practical guidance for MNEs navigating the digital transformation. It presents use cases illustrating the complexities of pricing GenAI tools and centralised cybersecurity services, and emphasises the need for robust functional analyses, documentation, and alignment with evolving regulatory frameworks.

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