TPA Global Webinars 2017-2018

 

Implementation of BEPS Action 13 - Argentina, Mexico and other countries of Central America

Whilst many countries around the world have been implementing Action 13 of BEPS, countries in Latin and Central America also continue gradually advancing in the incorporation of the Country by Country report, Master File and Local file in their domestic legislation and therefore assuming the new challenges on transfer pricing documentation recommended by the OECD.

In this context, we would like to invite you to our next webinars where we will discuss with our TPA LATAM Global Alliance Partners as regards the implementation of the Action 13 of BEPS in Argentina, Chile, Colombia, Peru, Uruguay, Mexico and other countries of Central America, the current status and the implications of this TP documentation requirements.

The webinars will consider the following:

  1. General presentation of the Argentine, Mexican and other Central Amercan countries' transfer pricing legislation incorporated in accordance with Action 13 of BEPS.
  2. Update of the actions that the mentioned countries have taken after such implementation.
  3. Implications of these new TP documentation requirements
  4. The main challenges faced by companies operating in the referred countries.

Speakers

Belisa Severini, Senior Associate
TPA Global, Argentina
 
Jorge De la Rosa, TPA Global Member
Grupo Consultor EFE™, Mexico
Ramon Lavara, TPA Global Alliance Partner
Lavara Transfer Pricing Consulting, S.C., Mexico
 
 

Wednesday, November 22, 2017

10:00 AM - 11:00 AM Mexico, USA and Canada
2:00 PM - 3:00 PM Brazil
4:00 PM - 5:00 PM London (GMT)
5:00 PM - 6:00 PM Amsterdam (CET)

Register (English)
 


The impact of BEPS Action 13 for MNEs operating in LATAM - Chile, Colombia, Mexico and Uruguay

Countries in LATAM as Chile, Colombia, Mexico and Uruguay have been implementing in their domestic legislations some or all of the three-tiered transfer pricing documentation (Country by Country report, Master File and Local file) recommended by the OECD on Action 13 of BEPS project.  Hence, multinational enterprises operating in the region are required to fill this new TP documentation in compliance with the OECD standards and the specific regulations of the particular country.

In this context, we would like to invite you to our webinar where our Alliance Partners in Chile, Colombia, Mexico and Uruguay will discuss about the implementation of the of the three-tiered documentation in these countries, the relevant characteristics of this documentation and as well the impact of these requirements for companies operating in the region.

The webinar will consider the following:

  1. General presentation of the Chilean, Colombian, Mexican and Uruguayan transfer pricing legislation incorporated in accordance with Action 13 of BEPS.
  2. Update of the actions that the mentioned countries have taken after such iplementation i.e. regulation and guidance.
  3. Impact of these new TP documentation requirements for MNEs operating in LATAM.
  4. The main challenges faced by companies operating in the referred countries.

Speakers

Sonia Catalina Muñoz Rodriquez, Associate
TPA Global, The Netherlands
 
Jorge De la Rosa, TPA Global Member
Grupo Consultor EFE™, Mexico
Ramón Lavara, TPA Global Alliance Partner
Lavara Transfer Pricing Consulting, S.C., Mexico
 
Alejandro Delgado, TPA Global Alliance partner
Colombia
Daniel Gadea, TPA Global Alliance partner
Uruguay
 
Claudio Salcedo, TPA Global Alliance partner
Chile

Tuesday, December 12, 2017

10:00 AM - 11:00 AM Mexico, USA and Canada
2:00 PM - 3:00 PM Brazil
4:00 PM - 5:00 PM London (GMT)
5:00 PM - 6:00 PM Amsterdam (CET)

Register (Spanish)
 


Increased controversy in Africa after BEPS – An analysis of recent TP disputes

A presentation on increased controversy expected after BEPS and the MLI in Africa, and an update on current TP disputes going to court in Africa.

9 African jurisdictions have signed the MLI: South Africa, Nigeria, Seychelles, Mauritius, Cameroon, Egypt, Gabon, Burkina Faso and Senegal. Although many more African countries attended the discussions leading up to the MLI, apparently only 2 countries’ representatives made any meaningful contributions to the discussions: South Africa and Mauritius. What does this indicate?

The increased controversies expected can be illustrated by the effect of the 2017 “draft” OECD Commentaries and the MLI on potential Permanent Establishments (“PEs”) in Africa. What risks emerge here?

For instance, a Swiss enterprise and head office supplies goods world-wide. Its logistics company in South Africa assists facilitating marketing, sales and conclusion of sales in South Africa. Potential PEs may now exist. In another case, a procurement company in Isle of Man arranges sales of raw products to the Group subsidiaries in Africa, including South Africa. Both South Africa and Isle of Man have signed the MLI. The 2 countries are currently negotiating a Double Tax Treaty. Potential PEs may come into existence if the DTT is concluded.

TPA Global has initiated a series of webinars covering the global impact of emerging BEPS developments on various international structures. In the 2nd webinar of this series, we will analyze the impact of BEPS Action points on PEs in Africa, and present some live TP cases going to court in Africa.

Key Highlights of the webinar:

  • Presentation of the following elements of BEPS dealing with PEs in Africa:
    • Action 7 – Permanent Establishments;
    • “draft” 2017 OECD Commentaries & MLI;
    • Actions 13 – MLI.
  • Presentation of various current TP disputes going to court in Africa:
    • Zimbabwe and reliance on its general anti-avoidance provision to make a TP adjustment;
    • Malawi and reliance on Article 9 of the Double Tax Treaty to make a TP adjustment;
    • South Africa and application of a hybrid application of the Profit Split Method and para 6.38 of the OECD TPG.

Speaker

Prof. Dr Daniel N. Erasmus
- Independent tax Advisor for TRM Daniel Erasmus Tax Court Practitioners
- Adjunct Professor of International Tax & Transfer Pricing, Thomas Jefferson School of Law, United States of America

Thursday, November 30, 2017

9:00 AM - 10:00 AM Mexico, USA and Canada
1:00 PM - 2:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)

Register (English)



The impact of BEPS Action 13 for MNEs operating in Argentina and PeruRegional integration of transfer  pricing in Center America

Countries in LATAM as Argentina and Peru have been implementing in their domestic legislations some or all of the three-tiered transfer pricing documentation (Country by Country report, Master File and Local file) recommended by the OECD on Action 13 of BEPS project.  Hence, multinational enterprises operating in the region are required to fill this new TP documentation in compliance with the OECD standards and the specific regulations of the particular country.

In this context, we would like to invite you to our webinar where our Alliance Partners in Chile, Colombia, Mexico and Uruguay will discuss about the implementation of the of the three-tiered documentation in these countries, the relevant characteristics of this documentation and as well the impact of these requirements for companies operating in the region.

The webinar will consider the following:

  1. Tax authorities in the referred countries.
  2. The regional integration of transfer pricing in Center America (Costa Rica, Guatemala, El Salvador, Honduras, Nicaragua and Panama) and the general presentation of the Argentinian and Peruvian transfer pricing legislation incorporated in accordance with Action 13 of BEPS.
  3. Update of the actions that the mentioned countries have taken after such implementation i.e. regulations and guidance.
  4. Impact of these new TP documentation requirements for MNEs operating in LATAM.
  5. The main challenges faced by companies and)

Speakers

Belisa Severini, Senior Associate
TPA Global, Argentina
 
Jorge De la Rosa, TPA Global Member
Grupo Consultor EFE™, Mexico
Luis Ugarelli, TPA Global Alliance Partner
Market Facilitators S.A.C., Peru
 
   

Thursday, January 11, 2017

9:00 AM - 10:00 AM Mexico, USA and Canada
1:00 PM - 2:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)

Register (Spanish)




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