Renewables and Energy

The Renewables and Energy sector is experiencing dramatic change both technologically and operationally; but also with respect to regulatory scrutiny, tax policy, transfer pricing compliance, and transfer pricing compliance. Governments and tax authorities are becoming more focused on aligning tax structures with real economic value generated in green energy supply chains; with multinational players increasingly investing in wind, solar, hydrogen, and battery storage projects globally requiring transfer pricing rules that ensure profit shifting risks are covered while still creating value creation.

OECD BEPS 2.0 (Pillar 1 and Pillar 2) has already had a significant impact on project-level profitability, minimum taxation thresholds (15% global minimum tax), entity structuring in this sector.

Supply chains involve intercompany R&D services, licensing of proprietary technology (e.g. solar panel designs or hydrogen electrolyzer intellectual property), shared services centers, and central procurement – each requiring extensive transfer pricing documentation and defensible pricing models.