Global Tax Pioneers

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Simplifying Global Minimum Tax Compliance:
Why Transfer Pricing and Tariff Strategy Matter Now More Than Ever

In a recent feature by ACCA's AB Magazine titled Global Tax Pioneers, Adriana Calderon, Director at Transfer Pricing Solutions Asia, joins other global tax experts to reflect on the seismic shifts brought about by the OECD’s Global Minimum Tax (GMT) framework. The article highlights the increased accountability of local subsidiaries, especially across Asia-Pacific, in managing GMT compliance under the GloBE rules (Pillar Two of BEPS 2.0).

Adriana shares that "Multinationals can no longer simply delegate GMT compliance to their headquarters," emphasising the evolving responsibilities for regional teams. The article also explores how GMT interacts with existing transfer pricing rules and tariff obligations, urging companies to adopt a more integrated approach.

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With the introduction of the Global Minimum Tax, transfer pricing and tariff planning are no longer stand-alone considerations. They now intersect directly with effective tax rates (ETRs), profit allocation, and compliance obligations. Transfer Pricing Solutions Asia is uniquely positioned to help multinational enterprises navigate this triad of complexity with confidence and clarity.

Our Global Minimum Tax Capabilities

Transfer Pricing Solutions Asia has developed a comprehensive suite of services to support MNEs with Global Minimum Tax readiness and reporting. We combine deep expertise in transfer pricing with proactive compliance strategies to ensure your global operations remain aligned and audit-ready.

Our Key Global Minimum Tax Services

1. Jurisdiction-by-Jurisdiction GMT Risk Assessment
We analyse your global group structure and perform jurisdictional effective tax rate (ETR) diagnostics to assess potential top-up tax exposure under QDMTT, IIR, and UTPR rules.

2. GMT Simulation and Top-up Tax Calculation
Our team builds tailored models to simulate top-up tax obligations, enabling strategic decisions before actual liabilities occur. This includes examining deferred tax assets and permanent differences.

3. GMT Policy Design and Roadmap
We help you design a group-wide policy that integrates GMT obligations with your existing transfer pricing arrangements, improving transparency and documentation.

4. Pillar Two Documentation and Reporting Support
We support the collection and organisation of financial and tax data necessary for GMT filings, including reconciliation of local GAAP and IFRS standards, substance-based income exclusions, and safe harbour applications.

5. Global Coordination and Governance
Our international reach allows us to provide seamless support across Asia-Pacific, Australia, the UAE and beyond, aligning local compliance with global strategy.

Transfer Pricing: Still Critical Under Global Minimum Tax

The introduction of Global Minimum Tax does not replace transfer pricing. In fact, it intensifies the need for accurate intercompany pricing and robust documentation. Under GMT, profit allocation must reflect economic substance, and transfer pricing becomes a critical lever to manage top-up tax risks. How we can help:

Benchmark intercompany transactions to ensure arm’s length pricing.
Align pricing structures with global ETR outcomes.
Conduct comparability analyses that consider GMT sensitivities.

We believe that combining strong transfer pricing policies with GMT compliance is not just a regulatory necessity but a strategic advantage for MNEs.

Tariff Assistance for MNEs: Why It Matters

With rising protectionism and shifting trade policies, tariffs are back in focus. For MNEs, tariff implications now directly affect not just customs duties but also transfer pricing and GMT calculations.

Transfer Pricing Solutions Asia provides tailored support to MNEs to manage tariff risks:

1. Tariff Benchmarking
We assess your industry’s customs and tariff environment and evaluate how it intersects with your transfer pricing models and cost structures.

2. Intercompany Transaction Review
We help you evaluate your supply chain and pricing models for opportunities to optimise customs valuations while maintaining GMT and TP compliance.

3. Strategic Planning for Dual Compliance
We create strategies that harmonise transfer pricing and tariff compliance to avoid duplication of tax burdens or inconsistent reporting across jurisdictions.

"Companies are now contending with three distinct regulatory frameworks: Global Minimum Tax, Transfer Pricing, and Tariffs. The key here is that this calculation has to be done on a jurisdiction‑by‑jurisdiction level, and there have to be some adjustments."

Adriana Calderon
Director, Transfer Pricing Solutions Asia

How Transfer Pricing Solutions can help?

At Transfer Pricing Solutions Asia we combine:

Technical Expertise: Our specialists are seasoned professionals in transfer pricing, international tax, and trade regulations.
Regional Reach: We operate across Singapore, Malaysia, Australia, and the UAE, offering local insight with global coordination.
Practical, Proactive and Cost-effective Solutions: Unlike larger consulting firms, we deliver actionable guidance without inflated costs.
Client-Centric Approach: We work closely with your team to ensure readiness, efficiency, and clarity at every step.

If your multinational group has consolidated revenues over €750 million, GMT is already impacting your tax landscape. Coupled with evolving transfer pricing rules and rising tariff complexity, it’s critical to have a cohesive, future-proof strategy.

Navigate Tax Regimes and Compliance with Ease.

From emerging subsidiaries to global enterprises, we provide practical, customized Transfer Pricing Solutions across Asia Pacific and beyond.