Transfer Pricing for Oil, Gas & Natural Resources Services

Global Transfer Pricing Strategies for the Energy, Oil & Gas Sector

Helping energy and natural resource companies structure cross-border operations, manage commodity pricing, and maintain compliance with global Transfer Pricing regulations.

Ensure global compliance with Transfer Pricing in the Automotive & Manufacturing industry.

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Leading transfer pricing firm
WHY CHOOSE US

Why Choose Us for Oil, Gas & Natural Resources Transfer Pricing?

Energy and resource companies operate in multiple tax jurisdictions with complex asset structures and commodity flows. Our Transfer Pricing services help establish transparent pricing models and defensible documentation that reflect commercial realities.

01

Transfer Pricing strategy

for exploration, production, and refining operations.
02

Benchmarking and economic analysis

for commodity transfers.
03

Documentation and compliance

aligned with OECD Transfer Pricing Guidelines.
04

Risk management and audit defense

for global upstream and downstream operations.
Oil, Gas & Natural Resources
Industries We Support

Specialized Transfer Pricing Support for the Energy & Resources Sector

Technology & Software Industry

Major Transfer Pricing Issues in Oil, Gas & Natural Resources

Energy companies face complex global operations involving commodity transfers, shared infrastructure, and joint ventures. Authorities such as the OECD and CRA (Canada Revenue Agency) closely monitor pricing of natural resources and profit allocation. Robust Transfer Pricing documentation and transparent methodologies are essential for compliance and audit defense.

Determining arm’s length prices for crude oil, gas, and refined products is a core Transfer Pricing challenge.
We benchmark against global indices like Platts and Argus to ensure defensible pricing.
Pipeline, storage, and terminal services are often shared between affiliates.
Proper allocation of costs under OECD Transfer Pricing Guidelines is crucial for compliance.
Pipeline, storage, and terminal services are often shared between affiliates.
Proper allocation of costs under OECD Transfer Pricing Guidelines is crucial for compliance.
Joint operating agreements require clear profit attribution between exploration, drilling, and distribution partners.
We help structure equitable and compliant Transfer Pricing policies.
Intercompany funding for seismic studies, R&D, and field development must reflect actual economic contribution.
Our Transfer Pricing studies align cost-sharing models with OECD principles.
Commodity price fluctuations and limited comparable data create uncertainty.
Our customized benchmarking models ensure pricing remains consistent and defensible across cycles.
We prepare master files, local files, and Country-by-Country reports to ensure global compliance with Transfer Pricing documentation requirements.
Energy and resource companies face increased scrutiny due to high-value cross-border trades.
We design risk mitigation and documentation strategies to minimize potential tax adjustments.
our pricing

Clear, Competitive Packages Tailored for Your Transfer Pricing Needs

Basic Transfer Pricing Benchmarking

$2,500 (one-time)
Coverage:
Benchmarking analysis for a single intercompany transaction.
Deliverables:
Industry-specific benchmarking study
Arm’s length pricing support
OECD-compliant benchmarking documentation
Perfect for businesses that only need standalone benchmarking without full documentation.

Standard Transfer Pricing Study

$3,500 (one-time)
Coverage:
Comprehensive transfer pricing study for one transaction type.
Deliverables:
Functional and economic analysis
Selection of the most appropriate transfer pricing method
Benchmarking analysis
Documentation (Master File & Local File) in line with OECD and CRA guidelines
Designed for businesses requiring a complete transfer pricing report for CRA compliance.

Premium Transfer Pricing Study

$4,500 (one-time)
Coverage:
Financial transaction benchmarking or two types of transactions.
Deliverables:
Benchmarking for intercompany financial transactions (e.g., loans, guarantees)
Full documentation package (Master File & Local File)
Strategic pricing insights and documentation for high-risk or high-value transactions
Ideal for businesses with complex structures or cross-border financial arrangements.
Our Team Experts

Experienced Transfer Pricing Advisors at Your Service

faq

Transfer Pricing for Oil, Gas & Natural Resources

Get clarity on the most common questions our clients ask about Transfer Pricing in the energy and natural resources sector.

Need Accurate Commodity Pricing and Stronger Compliance?

Energy and resource companies engage in high-value cross-border transactions involving commodities, services, and joint ventures. Without proper documentation, you risk penalties, tax adjustments, and compliance issues. Our Transfer Pricing documentation ensures your pricing policies are OECD-aligned and defensible before tax authorities.

We prepare comprehensive documentation including:

  • Master File and Local File reports (as per OECD guidelines)
  • Country-by-Country Reporting (CbCR)
  • Benchmarking analysis for commodity pricing
  • Functional and risk profiles for upstream and downstream operations

Commodity markets are inherently volatile, and comparable data can be scarce. We apply customized benchmarking models using market indices (like Platts or Argus) and statistical adjustments to establish arm’s length ranges that withstand audit scrutiny.

Yes. We assist clients during audits and disputes by providing transfer pricing audit defence, reconciliation analysis, and documentation updates that align with CRA and OECD Transfer Pricing Guidelines.

Absolutely. Our Transfer Pricing specialists have experience advising leading energy, mining, and renewable resource companies. We understand the valuation of joint ventures, service agreements, and cost-sharing models specific to this sector.

We work with clients globally, with a strong focus on Canada, the United States, Europe, and Asia-Pacific. Our cross-border documentation ensures consistency and compliance across multiple tax jurisdictions.