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July 26th, 2016
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How Value Chain Analysis can contribute to managing controversy effectively

Looking for a specific category or topic? Click here

 

How Value Chain Analysis can contribute to managing controversy effectively

VCA is a holistic and realistic picture of how MNE runs its business and how that leads to taxation. A quantified assessment of how profits are located across an MNE’s global value chain is a 'must have’ in today’s BEPS environment.

This webinar is an excellent opportunity for CFOs, Heads of Tax and Transfer Pricing Departments to

  • with how the compliance documentation discloses “tax and commercial” sensitive data;
  • acquire a holistic overview of how VCA can be applied for preparing a defense to all stakeholders and managing controversy; and
  • be acquainted with the quantified value and contribution from a financial, tax and operational perspective applied to an MNE’s global value chain.


How to fight State Aid cases through a full "value chain analysis" - the Starbucks and Apple cases?

During this webinar the following highlights and aspects of using the value chain analysis approach will be addressed:

  1. Is including a value chain analysis an imperative for a robust TP documentation?
  2. How to align the value chain analysis with the financial data of the multinational?
  3. Is a value chain analysis prerequisite when concluding uni/bi/multi-lateral APA’s?
  4. Does a value chain analysis protect against European State Aid claims; even without an APA?

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Why is Value Chain Analysis critical in a BEPS environment?

The webinar will consider:

  1. How a value chain analysis will fully align the corporate governance framework, operating model and the tax/ TP structure of a MNE.
  2. How a value chain analysis will help in aligning the inconsistencies between the five layers of TP documentation within a MNE: master file, local file, Country-by-Country reporting, local TP forms and corporate tax returns.
  3. How a value chain analysis will help in aligning economic and functional conduct of the entities in a MNE in order to achieve the appropriate split of profit.
  4. How a value chain analysis can be used to identify the key value drivers of a MNE and allocate the profit in relation to such value drivers.

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Should Apple Pay $13 billion Penalty to EU?: Base Erosion and Profit Shifting (BEPS) and Transfer Pricing in MNCs

During this webinar the highlights addressed will be the following:

  1. Current tax policies and Update on BEPS Project of the OECD
  2. BEPS sensitivity on tax and transfer pricing preferential regimes
  3. Waves of tax challenges coinciding with BEPS Action plan
  4. Analysis of Apple vs. EU Commission case
  5. Challenges and opportunities for academic research

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How through a proper Value Chain Analysis the tax payer takes in control of the new generation of TP documentation requirements (BEPS Action 13).

During this webinar the highlights addressed in using the VCA approach will be the following:

  1. How has the VCA become so imperative in building a robust TP documentation?
  2. How should a proper VCA help in addressing the increased level of disclosure of MNEs’ tax and financial data for the TP documentation purposes?
  3. Meeting the new Master File Requirements and explaining MNE group’s profitability in Country-By-Country Reporting (‘CbCr’).
  4. How to align and build a consistent story in the disclosures through the 5 layers of TP documentation, i.e. Master File, Local File, CbCr, Local TP form, Tax Return?
  5. Effective communication of tax strategy to stakeholders - for clarity and simplicity in discussions with key business stakeholders.

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Global TP Risk Management

An informative webinar addressing ‘Global TP risk management’, particularly in order to understand how to achieve an effective control of the TP system within your organization. The webinar will cover the following topics:

  • Additional compliance burden and a higher demand for the time spent by (in-house) Tax & TP teams on TP planning and documentation
  • Role of economic substance in your intercompany pricing
  • Whether three realities, i.e. legal, financial and economic are aligned
  • How to set up a TP control framework?
  • Who is responsible for the TP control framework?
  • How to make the TP  control framework as part of the business control framework?

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TP Audit support & Controversy

This webinar is an excellent opportunity for experienced tax professionals in MNEs, who have dealt with completing the stages of compliance and risk management, to be in a better position to handle transfer pricing disputes. The highlights addressed in this webinar will be the following:

  • How should businesses be addressing the increased level of disputes?
  • What are possible dispute avoidance and dispute resolution tools?
  • How to prepare for a transfer pricing audit?

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Can BEPS Challenges be mitigated by moving to a central operating model?

This webinar is an excellent opportunity for CFOs, Heads of Tax, Transfer Pricing Departments, as well as for Supply Chain Managers, Business Managers  to

  • become acquainted with the main features of  a Centrally Managed Operating Model;
  • understand the potential operational, tax and financial benefits of  implementing such a model;
  • recognise how operating under such a centrally managed operating model may minimise MNEs’ tax/ transfer pricing exposures arising from BEPS Action Plans 8 –10 (e.g., substance requirements, value creation, control over risks);
  • acquire a holistic view of the steps required to implement  such a model; and
  • familiarize themselves with the potential challenges of moving toward a more centrally management operating model and how to overcome these.

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Intercompany Financing Structures Redefined (2)

The prevailing economic climate is impacting the risk appetite of lenders as more and more companies are defaulting on intercompany financial payments due to falling profits, although the current monetary policy from central banks across developed markets, like Europe, the US, and Japan is driving interest rates to record low levels to boost economic activity by encouraging lending.

The webinar focussed on the following:

  • Tax regulatory/BEPS changes by providing some practical examples like showing how current flow-through, cash pool/treasury, intercompany loans, guarantee etc have changed/will change due to changing economic climate and non-tax and tax regulatory changes;
  • Enumerate key regulatory changes impacting various financing structures, including intercompany;
  • Deliberate on different intercompany financing structures, such as cash pool, treasury bank, financial-flow-throughs, guarantees, hybrids (such as profit participation loans);
  • Analysing the impact of economic and regulatory changes on intercompany financing structures; and
  • Steps MNEs should take to bring their intercompany financial structures in line with those changes.

This webinar was addressed to CFOs, Heads of Tax/Transfer Pricing and anyone else in the organization who also wants to know the new rules of the game for intercompany financing structures.

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The future of intercompany financing (1)

The prevailing economic climate is impacting the risk appetite of lenders as more and more companies are defaulting on intercompany financial payments due to falling profits, although the current monetary policy from central banks across developed markets, like Europe, the US, and Japan is driving interest rates to record low levels to boost economic activity by encouraging lending.

The webinar will focus on the following:

  • Discuss the changes in current economic climate and how it is impacting the general financing environment
  • Enumerate key regulatory changes impacting various financing structures, including intercompany
  • Deliberate on different intercompany financing structures, such as cash pool, treasury bank, financial-flow-throughs, guarantees, hybrids (such as profit participation loans), etc. 
  • Analysing the impact of economic and regulatory changes on intercompany financing structures
  • Steps MNEs should take to bring their intercompany financial structures in line with those changes.

This webinar is addressed to CFOs, Heads of Tax/Transfer Pricing and anyone else in the organization who also wants to know the new rules of the game for intercompany financing structures.

Download the presentation      Watch the recording



Is Digitization Making Transfer Pricing Invisible?

The digital era has largely transformed the way multinational corporations do business and most of all, the goods they transact and the way they interact.
OECD noticed that national tax laws did not keep pace with globalisation of corporations and the digital economy. This left room for multinational corporations to exploit gaps that exist in domestic systems to artificially reduce their taxes. The final report by OECD “Action 1 - Addressing The Tax Challenges of The Digital Economy” was released in October 2015. In the report OECD identifies certain challenges of the digital economy direct and indirect taxes and proposes possible methods for tackling these.

This webinar will:

  • Discuss the latest trends in relation to digital economy and new business model configurations
  • Take a glance at traditional industries which now have joined the digital tide
  • Walk you through the key tax and transfer pricing issues related to the newly emerged business models:
    • Difficulties in identifying intra-group transactions of one entity/ international transactions involving intangibles
    • Effects on the performance of functional analysis
    • Challenges in applying traditional transfer pricing methods to determine the arm’s length price
    • Extra efforts required to find third party transactions which meet sufficient comparability criteria
    • Present alternative approaches for ensuring fair and timely taxation of the digital sector

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"Are you in Control now" - BEPS Health check

Since the impact of the new guidelines to combat BEPS as issued by the OECD and EU is actually bundled through disclosure of tax information to the outside world, it is an important point of attention for tax payers. This webinar will help you how to scan risks for own-risk assessment in disclosing tax information to be ready for the new post-BEPS tax and transfer pricing world. After this webinar you will be able to identify those risks requiring your immediate attention to focus on.

This webinar will address the following:

  • What are the new requirements for disclosure of tax information by MNEs according to the new OECD and EU guidelines?
  • Which questions should MNEs ask for own-risk assessment in disclosing tax information by multinational enterprises?
  • What solutions are available to MNEs to adopt a proactive approach in being BEPS compliant in the context of disclosing tax information?

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The UK Diverted Profit tax: Major Challenges and Practical Considerations

The UK’s Diverted Profit Tax (DPT) or ’Google Tax’ as often dubbed by the British media, is a new tax effective 1 April 2015, introduced by the Chancellor as part of Finance (No.2) Bill 2015.
TPA will provide you with a high level overview of the latest developments in the DPT rules and use common multinational case-studies to demonstrate how new rules may affect multinational enterprises and how those enterprises should respond to DPT challenges in order to mitigate/ eliminate DPT risks.

The webinar will address the following:

  • Elaborate on the latest developments of the UK DPT rule
  • Address the major risk areas for multinationals in relation to UK DPT
  • Discuss practical case studies to demonstrate how extensively DPT rules may apply to multinationals
  • Present what practical solutions are available to mitigate/ eliminate UK DPT risks

Download the presentation       Watch the recording   



BEPS in LATAM - A holistic analysis and Mexico as Practical case

EU countries, USA, Canada, Australia and other OECD member countries have been actively promoting how and to what extent their countries will be introducing BEPS measurements into their tax and financial systems. In the case of LATAM countries the majority are not OECD members and their contribution to BEPS measurements has been limited. Nevertheless, some LATAM countries already have or have announced to implicitly or explicitly implement regulations that are anti-BEPS.  For those multinationals with operations in the LATAM region, it may still be unclear how, when and which of the 15 BEPS action points will be implemented in the tax systems of the LATAM countries.

The webinar addresses the following:

  1. Which BEPS actions plans will become effective in LATAM as from 2016 and what will be their potential effect to your LATAM finance and tax books?
  2. How should MNEs with operations in LATAM react to such LATAM BEPS-related initiatives?
  3. What solutions are available to MNEs to adopt a proactive approach in being BEPS compliant in the context of LATAM regulations?

Download the presentation      Watch the recording 


 

Simplified Assessment of BEPS-related risks to be reported before year-end

Today tax executives are feeling the heat due to increasing pressure to improve efficiency, grow revenues and ensure control. Increasing regulatory requirements under BEPS are making “being in control” much more challenging. In such a complex business environment, each multinational organization is in greater need of a tax risk management process that has the right balance between risk and opportunity for further growth.

TPA Global, therefore, presents to you its informative webinar addressing BEPS specific risks, which your organisation may be obliged to report by the end of this year.

The webinar considers the following:

  1. Additional compliance burden and a higher demand for the time spent by (in-house) Tax & TP teams on TP planning and documentation.
  2. Additional recommendations created by OECD to disallow attribution of significant profits to group entities within a multinational claiming to perform activities (e.g., management of intellectual property), unless certain conditions are met.
  3. Additional recommendations created for countries to establish a fixed cap for deduction of interest, within a range of 10%-30% of either EBIT or EBITDA.
  4. Revisions that are proposed to the definition of the taxable presence (i.e., tax treaty definition of a permanent establishment) which will make it more difficult for a firm to avoid attributing profits from sales in a country with an affiliate or agent.

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Latest Transfer Pricing Developments in India

Lately there has been a great emphasis on reduction of litigation, with both Tax payers and the revenue authorities being involved on confidence building measures and regulations such as APA’s, safe harbors and dispute resolution panel being introduced to mitigate the unnecessary litigation and uncertainties in the transfer pricing regime.  

India has been closely observing OECD’s BEPS initiatives and is likely to come up with its own guidance in the short future for implementing international measures that will promote tax transparency for all stake holders.

At the end of the webinar, you will:
  1. Understand the latest developments in the Indian transfer pricing regime;
  2. Identify the key controversial issues leading to litigation;
  3. Realize key measures to mitigate litigation risk.

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BEPS' Action Plan 13 influence on Pan-LATAM MNCs

[BEPS - Action 13] A total of 44 countries, are participating in the BEPS project on an equal footing. Within these group of elite countries only a few are in Latin American (LATAM) – Argentina, Brazil, Chile, Colombia, Costa Rica and Mexico – each having a different degree of involvement in the implementation of BEPS initiatives. Thus far only Mexico has recently proposed the introduction of specific BEPS initiatives relating to Action plan 13 in its tax system that if approved would take effect as from 1 January 2016. Considering these facts, what can be expected from these countries and from other LATAM countries in the context of Action plan 13? Your organization may probably be asking the same question.

At the end of the webinar, you will:
  1. Understand how internal and external factors will influence the LATAM approach to promoting the implementation of Action plan 13;
  2. Identify the LATAM countries expected to lead the ‘tax transparency’ era and the potential implications of their initiatives to your company.
  3. Realise the benefits for implementing a consistent, secure and cost-effective approach to tackle Action plan 13 initiatives in the context of your company’s operations in LATAM.

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Are you "in control"? Towards a 50% more efficient TP compliance cycle

[BEPS - Action 13] Considering this complex range of regulations, a fundamental question emerges: “How can organizations create a governance and control framework which would ensure that tax/TP function is managed and controlled in a timely, cost effective and efficient manner?”

TPA Global brings the answer to you in the form of automated TP software solutions which, when combined with TP organisational and operational best practices, can increase the efficiency of your TP compliance cycle by 50%. This webinar will assist you in identifying the requirements specific to your business that can be automated through one or more software functionalities.

This webinar will follow a three-pronged approach to touch upon the following:
  1. How to achieve a 50% more efficient TP compliance cycle
  2. How can TP software solutions assist?
  3. Q&A session with software providers

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China Transfer Pricing and Anti-tax avoidance update

TPA Global, together with MinterPKU, will provide you with a high level overview of the new rules and use common multinational case-studies to show you just how extensively the new rules are likely to apply.

The webinar considers the following:

  • China transfer pricing overview in 2015
  • Recent transfer pricing changes in practice
  • The new measures for GAAR and Cost Sharing Arrangement administration
  • Case studies: cross-border service fee and royalty payments

Download the presentation      Watch the recording



The 2015 Transfer Pricing Challenge: automation of your “country-by-country” reporting

Action 13 of the OECD/G20 BEPS project “Guidance on Transfer Pricing Documentation and Country by Country Reporting” can be considered to be one of the key deliverables. The action proposes to enhance transparency for tax administrations and contains revised standards for transfer pricing documentation and consists of three layers of documentation:

  1. a global Masterfile for transfer pricing
  2. a local transfer pricing documentation file
  3. a Country by Country report consisting of two tables

The webinar will address the following:

  • Address a practical way to source & automate Country by Country data collection
  • Provide all participants with a Country by Country instruction manual
  • Provide solutions on how to complete the 2 tables requested by the tax authorities
  • Provide disclosure options to be discussed with your CFO
  • Run a list of FAQ per category of stakeholders

Download the presentation    Watch the recording



BEPS – Where is BEPS today?

Today finance and tax in-house executives are feeling the heat due to enduring pressure to promote transparency, grow the business and ensure control to be considered a “good corporate citizen”. Increasing requirements are making “being in control” even more challenging. In July 2013, OECD – the global guiding institute on tax and transfer pricing issues, released an Action Plan on Base Erosion and Profit Shifting (BEPS). The BEPS action plan sets forth 15 actions aimed to address tax planning strategies that exploit gaps and mismatches in tax rules or shift profits to locations where there is little or no activity. These actions will result in fundamental changes to the international tax and transfer pricing standards. Given the increasing attention to addressing BEPS, OECD has scheduled to finalize and implement the related guidelines still in 2015.

The webinar will address the following:

  • The status and key discussion points with respect to the 15 BEPS actions;
  • Address and define the different types of transfer pricing risks, including technical, operational, compliance, financial statement, management and reputational;
  • Visualize the methodologies of a BEPS readiness test;
  • Explain how to mitigate tax risks in the BEPS period.

Download the presentation     Watch the recording



A Plain English Guide to the UK Diverted Profits Tax

A guide to assessing how the new UK Diverted Profit Tax, effective 1 April 2015, will apply to your UK and international operations and your UK reporting obligations.

The UK’s Diverted Profit Tax (DPT) or ’Google Tax’ as often dubbed by the British media, is a new tax effective 1 April 2015, introduced by the Chancellor as part of Finance (No.2) Bill 2015. The new charge (levied at 25%) is purported to be aimed at tackling aggressive international tax planning techniques used by large multinational corporations, in response to the view that the rafts of existing UK tax legislation do not go far enough in protecting the UK’s tax base. However, the reality is such that the rules are likely to have far wider application.  

The webinar will consider the following:

  • Elaborate on the two key charging provisions of the UK DPT;
  • Application of the “80% payment test;
  • The “Insufficient Economic Substance Condition”;
  • The reporting obligations under DPT (even if it is likely that no DPT charge would arise); and
  • How the DPT may be calculated.

Download the presentation      Watch the recording


 

Are you “in control”? - Transfer pricing “in control” assessment

TPA Global has developed a Transfer Pricing “in control” assessment to help you evaluate the performance of your TP function and define an “in control” statement on your TP processes. The starting point for organizing the structure of the in-house tax function is a decision as to what are the key focus areas. TPA has defined the nine building blocks (workflows) of a successful in-house TP function which is at the core of TP “in control” assessment. This assessment captures insights across those nine workflows and not only helps you to get the overall ‘as is’ picture of your company’s TP function but also allows you to better understand how to bridge the gap between the current practice and the desired level to minimize potential tax and transfer pricing risks.

The recording will address the following:

  • Discusses the concept of transfer pricing governance;
  • Presents TPA’s practical approach to transfer pricing governance;
  • Visualize the methodologies of Transfer pricing “in control” assessment; and
  • Suggests how to improve your transfer pricing function.

Download the presentation      Watch the recording


 

The Indonesian TP environment: where are we now?

In this major and growing economy both the tax authorities and courts in Indonesia have made their first steps into the new world of transfer pricing rules and regulations. The practice of the local tax authorities is often different from the written rules and TPA will share some of its recent TP audit experience. Since trade rules and regulations get stricter on certain products, TPA is also expecting similar trends in Indonesia on transfer pricing implementation. How does Indonesia look at the TP and FDI policies of surrounding countries?

The recording will address the following:

  • The Indonesian economy and the tax and TP environment
  • The practical aspects of TP compliance in Indonesia
  • What might be the expected impact from regional and global developments

Download the presentation       Watch the recording


 

Russia - TP legislation and Practical approach to transfer pricing compliance

The new set of TP rules and regulations in Russia have just been launched and implemented. How is this first cycle of TP documentation in Russia going to be supporting your case? Are the transactional approach on TP documentation going to be the standard for Russia and all its neighboring countries? TPA shares firsthand experience on a country looking at TP rules and regulations for the first time, with a major focus on local-to-local transactions.

The recording will address the following:

  • Overview of TP Rules in Russia;
  • Main differences between common practice and TP rules in Russia;
  • Attention points TP compliance in Russia;
  • Practical approach to TP compliance.

Download the presentation      Watch the recording



Shaping the tax future of MNCs with operations in Brazil

As tax administrations and international economic organisations reach consensus for implementing international measures that will promote tax transparency amongst the business community, uncertainties rise around the scope and extent of some of the action points proposed to drive tax transparency between jurisdictions. However, one thing is for sure: drastic changes to the global tax framework will occur in the short-medium term and these will impact MNCs’ investment decisions and their flow of income.

In the process of revitalising international taxation the implementation of global tax transparency standards will be paired with regional and country-specific ones to address local-specific issues. In this process, where does Brazil stand? What should your company expect from the involvement of Brazil in the development of tax transparency standards? Has your company developed a model of exchange of tax and transfer pricing information within the group for Brazil-related tax and transfer pricing matters?

The recording will address the following:

  • The internal and external factors driving international taxation and transfer pricing in Brazil;
  • Particularities of the Brazilian transfer pricing rules in comparison to internationally recognized standards; and
  • Mechanics of the transfer pricing methods available in Brazil, existing safe-harbors, as well as compliance related aspects.

Download the presentation      Watch the recording



The 2015 Transfer Pricing Challenge: automation of your “country-by-country” reporting

Action 13 of the OECD/G20 BEPS project “Guidance on Transfer Pricing Documentation and Country by Country Reporting” can be considered to be one of the key deliverables. The action proposes to enhance transparency for tax administrations and contains revised standards for transfer pricing documentation and consists of three layers of documentation:

  1. a global Masterfile for transfer pricing
  2. a local transfer pricing documentation file
  3. a Country by Country report consisting of two tables

The recording will address the following:

  • Address a practical way to source & automate Country by Country data collection
  • Provide all participants with a Country by Country instruction manual
  • Provide solutions on how to complete the 2 tables requested by the tax authorities
  • Provide disclosure options to be discussed with your CFO
  • Run a list of FAQ per category of stakeholders

Download the presentation      Watch the recording


BEPS – Where is BEPS today?

Today finance and tax in-house executives are feeling the heat due to enduring pressure to promote transparency, grow the business and ensure control to be considered a “good corporate citizen”. Increasing requirements are making “being in control” even more challenging. In July 2013, OECD – the global guiding institute on tax and transfer pricing issues, released an Action Plan on Base Erosion and Profit Shifting (BEPS). The BEPS action plan sets forth 15 actions aimed to address tax planning strategies that exploit gaps and mismatches in tax rules or shift profits to locations where there is little or no activity. These actions will result in fundamental changes to the international tax and transfer pricing standards. Given the increasing attention to addressing BEPS, OECD has scheduled to finalize and implement the related guidelines in 2015.

The recording will address the following:

  • Present “best practices” in tax risk management and global tax practices;
  • Address and define the different types of transfer pricing risks, including technical, operational, compliance, financial statement, management and reputational;
  • Visualize the methodologies of a BEPS readiness test;
  • Explain how to mitigate tax risks in the BEPS period.

Download the presentation    Watch the event recording



Shaping the tax future of MNCs with operations in the LATAM & Caribbean region

As tax administrations and international economic organisations reach consensus for implementing international measures that will promote tax transparency amongst the business community, uncertainties rise around the scope and extent of some of the action points proposed to drive tax transparency between jurisdictions. However, one thing is for sure: drastic changes to the global tax framework will occur in the short-medium term and these will impact MNCs’ investment decisions and their flow of income.

In the process of revitalising international taxation the implementation of global tax transparency standards will be paired with regional and country-specific ones to address local-specific issues. In this process, where does the LATAM and Caribbean (“LAC”) region stands? What should your company expect from the involvement of the LAC governments in the development of tax transparency standards for the region? Is your company ready to become ‘tax transparent’ with respect to its tax and transfer pricing systems for the LAC region? Has your company developed a model of exchange of tax and transfer pricing information within the group for LAC-related tax and transfer pricing matters?

The recording will address the following:

  • The internal and external factors driving international taxation and transfer pricing in the LAC region;
  • The capabilities, expertise and resources available to the LAC tax authorities in the area of international taxation and transfer pricing; and
  • Regional solutions available to MNCs for shaping and controlling their tax and transfer pricing future in the LAC region.

Download the presentation      Watch the event recording


 

Guaranteeing the performance of a related party – an arm’s length view

Due to globalization and the size of MNCs, performance guarantee arrangements, within a MNC group, are common and growing.

Performance guarantee is relatively a new area of transfer pricing concern for taxpayers as there is not much guidance available from the OECD or tax authorities. Performance guarantee arrangements enter the transfer pricing realm when a related party (usually the parent) supports the commercial contracts of another member of the group by issuing a corporate guarantee (or a bank’s standby letter of credit  drawn on the parent’s credit facilities) to a counterparty.

A considerable amount of discussion is being generated regarding the implications of performance guarantee for transfer pricing purposes. The attention garnered by performance guarantee fees is likely to increase in the next few years. It would be easier to defend performance guarantee arrangements before tax authorities if you have identified the performance guarantees, determined the arm’s length pricing (i.e., quantum of the guarantee fee) and have an appropriate level of documentation.

The recording will address the following:

  • Overview of performance guarantees;
  • Roles of the parties to the performance guarantee arrangement;
  • Whether performance guarantee fee should always be charged between related parties; and
  • Methodologies to price performance guarantees

Download the presentation      Watch the event recording


 

Treatments for inbound and outbound intercompany transactions in China

In recent years, with China playing a key role in the world economy, the number of intercompany transactions with foreign affiliates in China have increased, i.e. provision of products or services, licensing of intangibles or granting loans to related parties. China has transfer pricing, thin capitalization and controlled foreign company rules, as well as a general anti-avoidance rule. In addition, China also has 19 types of tax levied. Therefore, conducting intercompany transactions with Chinese affiliates is more complicated than conducting the same transactions in many other countries.

Understanding the rules and regulations and then following them consistently will result in a relatively smooth flow for the related intercompany transactions. In order to assist Multinational Enterprises (MNEs) with respect to transfer pricing risks and avoiding double taxation issues, in the web event we will discuss the tax consequences of charges for intercompany transactions from a Chinese tax law and transfer pricing perspective.

The recording will address the following:

  • The relevant types of Chinese tax involved in inbound and outbound intercompany transactions
  • The tax consequence of charges for inbound and outbound intercompany transactions 

Download the presentation     Watch the event recording

TPA Global e-Archive
; posted on
July 26th, 2016
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How Value Chain Analysis can contribute to managing controversy effectively

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