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

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

A Value Chain Analysis (‘VCA’) considers an end to end view of a company’s activities, enabling a better perspective on the way a business works and how each component contributes and creates value. By way of the VCA, taxpayers can more easily assess the relative importance of different contributions across a whole multinational enterprises’ (‘MNEs’) value chain. This has many different and important applications for tax and transfer pricing (‘TP’).

The changes proposed by the OECD BEPS Action Plan in October 2015 have the potential to radically change tax and transfer pricing outcomes for many taxpayers. The realignment of taxing rights with economic substance is at the heart of the initiative by applying a 2-sided approach to find whether taxpayers comply with the arm’s length principle. In other words, there is also an increasing need to study TP beyond two transacting parties, in terms of how the contributions made by them lead to the generation of profit for a business in the value chain. The focus of the in-depth analysis should, more than ever before, be on identifying the economically significant and value creating functions within a business and their impact on intercompany pricing, and the parties responsible for those functions.

This webinar is an excellent opportunity for experienced tax professionals in MNEs to be in a better position to handle the new TP documentation requirements globally with the help of a proper VCA.

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.

Wednesday, 28 September 2016

9:00 AM - 10:00 AM USA, Canada, Mexico (CST)
3:00 PM - 4:00 PM   London (GMT)
4:00 PM - 5:00 PM   Amsterdam (CET)

Register now


Transfer Pricing Associates introduces TPA BEPS Desk. If you have any questions, or need more detailed advice on any aspects of BEPS related issues, please get in touch with us. The TPA Global network has alliance partners throughout the world, and the network can provide multi-disciplinary approach on today's critical transfer pricing challenges faced by multinational enterprises.

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