TPA Global Insight
Top Transfer Pricing Challenges for the Agricommodities Industry (BEPS)
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October 28th, 2016
Authors: Steef Huibregtse is the CEO and the founding partner of TPA Global and Katerina Miari is an Associate at TPA Global in Amsterdam.
The complexities of transfer pricing, particularly in the midst of BEPS-driven reforms, have created significant burdens for multinational enterprises.
Value Chain Analysis - The BEPS Generation of Functional Analysis (2)
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September 26th, 2016
The value chain for any firm links value-creating processes and activities. It refers to the entire performance process of a company, which begins with the research and development and ends with the delivery to the end consumer.
Revitalizing Your Digital Strategy | Tax scandles and strategic challenges faced by Apple in 2016!
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September 22nd, 2016
A 13 billion tax penalty for Apple, yet who’s to blame? Apple had sweet-heart deals paying less than 1% tax since 2004.
According to Apple, no laws were broken, the tax breaks were permitted by the Irish government.
How through a proper Value Chain Analysis the tax payer takes in control of the new generation of TP documentation requirements (BEPS Action 13)
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September 19th, 2016
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.
China Policy in the Lead – A Full Value Chain Analysis for FY 2016 required
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September 1st, 2016
The China State Administration of Taxation ("SAT"), on June 29, 2016 issued "the Public Notice on Matters Regarding Refining the Filing of Related Party Transactions and Administration of Contemporaneous Transfer Pricing (“TP”) Documentation Public Notice of the State Administration of Taxation [2016] 42” ("Notice 42"), which replaced certain sections laid down in “Guoshuifa [2008] Circular 114 in relation to annual filing of related party transactions and certain sections laid down in the “Guoshuifa [2009] (“Circular 2”) in relation to contemporaneous TP documentation.
Notice 42 mainly reflects the Chinese tax authority’s position in responding the international standard set out in the OECD/G20 BEPS Action 13 ~~ (“Action 13”) in relation to TP documentation and country-by-country (“CbC”) reporting.
Corporate ‘Tax’ Governance: A Necessary Addition to Best Practices for Businesses?
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September 1st, 2016
Management of an entity’s tax strategy has historically been down to finance directors and has received little attention from boards. However, the growing reputational risk attached to strategies that incur a notably low tax bite and the ensuing BEPS project has forced boards to focus on their taxes as much as they do other areas of corporate governance.
How To Make Intercompany Loans BEPS Proof
; posted on
March 17th, 2016
Authors: Steef Huibregtse, Virender Sharma and Maria Grigoryeva (consultants at TPA Global)
Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year. In the light of the aforementioned, and the current practice of MNEs on intercompany loans, this article delves into 4 “true or false” statements which are relevant for various stakeholders including MNEs to ponder over.

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