TPA Global (web) Events 2018

TPA Global is facilitating a workshop on ‘global tax controversy’ for corporate taxpayers where a team of globally renowned, independent specialists (see www.gtc-global.org for more details of the speakers) with wide-ranging experience in value chain analysis, arbitration, mediation, litigation and tax rulings, are invited to discuss these issues with corporate taxpayers in an interactive workshop setting.

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International tax and Transfer Pricing landscape has witnessed reformatory transformation in recent years, especially after the launch of Base Erosion and Profit Shifting (BEPS) Action Steps in 2013 and subsequent issuance of the final measures in October 2015.

India has an observer status with OECD, represents G20 countries and is an active participant in OECD’s initiatives. India has applied several BEPS recommendations in last few years, namely signing of Multilateral Instruments, introduction of Country by Country Reporting (CbCR), Master file, secondary adjustments, GAAR, thin capitalisation rules, reinforcing substance requirement in the tax statute with inclusion of Significant Economic Presence there. Several landmark judgements have also been pronounced on key international tax issues.

The MNEs operating in India therefore need to examine and align their tax positions and Transfer Pricing documentation and Policies with these changes. It becomes essential for the tax and finance department in the MNE to gain an understanding of the plausible impact, issues and solutions surrounding the transformed international tax and transfer pricing landscape, in order to plan their risk mitigation strategies appropriately.

Key Highlights of the webinar

In that regard, this Webinar analyses the following:

  • Does Action 13 change the attractiveness of unilateral APAs in India?
  • Are the issues surrounding Marketing intangibles, characterisation of Captive R&D Centres and secondary adjustments resolved?
  • What is the BEPS Impact of Business Connection expanded through ‘Significant Economic Presence’?
  • Discussion on the landmark judgements on Permanent Establishment, such as Formula One and E-Funds, and the views on Profit Attribution in India – Global Formulary Approach vs. FAR Analysis?
  • India’s MLI Position - Interplay of GAAR and PPT for countering treaty abuse
  • Indirect transfers law – Pending unaddressed issues post issuance of Final Valuation Rules

Please join this Webinar for an interactive deliberation on the covered topics.

Speakers

Thursday, 3 May, 2018

6:30 AM - 7:30 AM Mexico, USA and Canada (CDT)
8:30 AM - 9:30 AM Brazil (BRT)
1:30 PM - 2:30 PM The Netherlands (CEST)
5:00 PM - 6:00 PM India (IST)
7:30 PM - 8:30 PM China (CST)

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Is your company up to date with the CbC challenges and risk analysis?

With the mandatory filing and automatic exchange of CbC reports that has been implemented by a number of countries, most MNEs have filed CbC reports with 2016 data and will file 2017 data before the end of this year. CbC Reporting is intended to provide increased transparency to tax authorities by providing a breakdown of where a MNE recognizes revenues and profits, the taxes paid on such profits, and certain other economic data such as tangible assets and headcount. Such CbC reports will be used by tax authorities to perform tax risk assessments based on the OECD Handbook on risk assessment and will likely lead to increased tax audits and controversy.  

We address this concern in our latest webinar (a part of the TPA Global’s knowledge sharing initiative of 2018) where we will not be the only ones presenting. Along with us our partner Palantir, a software provider with a web-based CbCR and entity management solution, will tell and show you their software solution. Together we will not only present the automated software solution that ensures appropriate and timely filing of CbC reports, but we will also focus on risk analysis together with the challenges to be kept in mind that emanate from an automated exchange of CbC reports between tax authorities from multiple countries. Next to this TPA will be pleased to present the newly developed SUITE 2020, showing the platform to the world for the very first time.

The webinar will consider the following:

  1. The who, what, when and how of preparing and filing a CbC report with Palantir?
  2. How to ensure that the information presented in the CbC report is aligned with your operating and governance models as well as presents a consistent storyline.
  3. How can automation help you in preparing and filing a CbC report?

Speakers

  • Peter Öhling, Palantir, Sweden
  • Jasper Verkamman, TPA Global, The Netherlands

Tuesday, May 15, 2018

9:00 AM - 10:00 AM Mexico, USA and Canada
11:00 AM - 12:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow

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Value Chain Analysis (VCA)

TPA Global has been conducting value chain analyses for over 10 years. With over 1000 professionals trained in value chain analyses, TPA Global is one of the world leaders in offering industry-specific value chain solutions!

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