TPA Global Videos

In a world that is moving at a fast pace in the light of the “disruptive” digitalization processes happening at the moment, it is essential for taxpayers to be aware of their rights and of the balance of power existing between them and the tax authorities (“TAs”).
In this webinar we will discuss rulings from the Dutch Supreme Court where the taxpayer’s right to be informed was assessed in the context of a mathematical calculation software.

Without doubt, the much-awaited judgments of the EU Court in Starbucks and Fiat have created an array of debates, from application of the concept of state aid to tax matters to redesign of transfer pricing concepts. Therefore, we bring to you three experts on the matter, Philip Baker, Hans van den Hurk and Steef Huibregtse, who will seek to answer some of these questions in a webinar and present their view on the judgement and what lies ahead for multinationals in Europe.

The BEPS Action Plans, in an attempt to tackle extreme cases of tax evasion, have inevitably blurred the line between strategic tax planning and fraudulent tax evasion for corporate taxpayers. This, coupled with latest publications of the OECD on ‘Fighting Tax Crime’ where taxpayers’ rights find a bleak mention as ‘suspects’ rights’ has given force to many governments to enact a number of aggressive (and often, unjust) regulations.

‘Qualitative and quantitative value chain analysis’ will prove to be a requisite tool as it is able to swiftly identify and resolve any mismatches between holistically applied value chain analysis and the transactional transfer pricing model of an MNE. Conducting of a qualitative and quantitative value chain analysis helps taxpayers to have certainty in respect of profits allocated to different value drivers across business segments, jurisdictions, and legal entities etc.

In this webinar, we will share practical insights with you on how to use value chain analysis for risk identification and prevention. We will also explain how to link your value chain components to controversy instruments.

The requirements for full disclosure after BEPS are affecting multinational corporations in one way or the other. In this world of complete transparency, one aspect of being fully in control is getting a strong grip on your intercompany costs.

The key to being “Fit For Future” will not lie in predicting it, but in preparing your organization to handle multiple changes at ones, utilizing all of your internal and external network to deliver competitive solutions to your customers. With this will come questions on control and governance and on the relationships between legal entities.

Technology is developing at the speed of light, and it is sometimes difficult to keep up with new features available in the market. Meanwhile, software sales people are knocking at the door and promising magic solutions that will solve all the problems.

The additional compliance burden of repetitive reports to be filed year after year may trigger boards to push for more automation of tax compliance tasks to keep compliance costs at reasonable levels and the quality thereof at higher levels versus the current manual reporting. In addition, the risk of double taxation has increased since tax authorities are now more aggressively fighting for “their fair share”.

In this age of digitization, it has become of utmost importance for companies to understand how to conduct a Value Chain Analysis which is streamlined for digital businesses. This is of increasing relevance as the classical qualitative methods to conduct a value chain analysis such as a Porter’s type of analyses are redundant for the digital businesses as they do not have standard business processes such as manufacturing, research and development, sales, marketing etc.

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.

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.

As G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, full tax transparency is the new norm. The global transfer pricing (“TP”) compliance has become more burdensome due to multiple deadlines and complex documentation requirements.

This informative webinar on major changes proposed in India’s Union Budget 2018 will help you to understand the fine print of some such latest changes and how they could impact your businesses.
Key Highlights of the webinar .

On 30 September 2017, a new corporate offence came into force in the UK aimed at businesses that fail to prevent the facilitation of tax evasion. The new rules do not change the scope of what constitutes tax evasion in the UK, but puts a requirement on businesses to put in place various preventative procedures.

In this video we will discuss the context of US tax reform, the key provisions (including new concepts) impacting international businesses, and explore some of the related tax impacts on business models. We will also discuss the practical implications and the need to re-evaluate global ETR planning and related business models in the aftermath of BEPS, US Tax Reform and other evolutions causing significant changes across the global tax landscape.

We are all aware that in the post-BEPS world, there are a multitude of compliance deadlines that each multinational enterprise (MNE) needs to bear in mind, in order to shield itself from disputes and penalties. These are crucial not just from a compliance point of view but also a risk management perspective as the penalties can sometime be overwhelming.

A presentation on the improvements BEPS has made to the resolution of international tax disputes through the Mutual Agreement Procedure (MAP) under tax treaties. TPA Global has initiated a series of webinars covering the global impact of emerging BEPS developments on various international structures.

Countries in LATAM as Argentina, Brazil and Peru have been implementing in their domestic legislations some or all of the three-tiered Transfer Pricing (TP) 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.

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 (TP) 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.

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.

In this webinar we will discuss with our TPA LATAM Global Alliance Partners the implementation of the Action 13 of BEPS in Argentina, Mexico and other countries of Central America, the current status and the implications of this TP documentation requirements.
The webinars will consider the following: .

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.
The webinars will consider the following: .

The scope of the transfer pricing obligations since January 1 st , 2017 is more extensive than that of previous years, so meeting the new obligations may be a complicated and time-consuming process. Therefore, it is recommended to verify potential obligations in the field of transfer pricing for your company and launch appropriate works as soon as possible.

[English version]
This recorded webinar will consider the following:

[Spanish version]
This recorded webinar will consider the following:

The webinar will cover the following 10 practical topics:
What are the important visual data analysis tools I should be using to detect BEPS tax risk and the ‘ false +ves ’ (no BEPS tax risk)?.

In the post-BEPS era, a surge in the number of deadlines to meet has led to an increase in the compliance burden. This, coupled with escalating disputes in numerous locations across the globe, leaves limited opportunities for cost savings and tax optimization.

TPA Global is initiating a series of webinars covering the global impact of the emerging BEPS developments on offshore structures. In the first webinar of this series, we will analyze the impact of applicable BEPS Action points on offshore structures from a global/OECD perspective and present some live cases impacted by these Action points and will end with recommendations to companies in similar situations.

尽管公平交易原则依旧是分析跨国企业关联交易的基础，但我们在实际分析的角度上已经发生了巨大变化。当今的时代要求我们从整体宏观的角度来分析关联交易 - 即对企业整体价值链进行全盘刨析来说明企业各集团公司都获得了相应的公平回报。
继2015年OECD 发布BEPS第13项行动计划之后，价值链分析已成为转让定价领域的焦点话题，一些政府纷纷出台关于使用价值链来分析企业各集团公司应得的利润，例如在价值链分析中披露企业各成员公司实际所得利润和其相应的财务报表等（特别是中国国税近期出台的转让定价同期资料新规（42号公告）- 明确要求企业在2016财年的转让定价本地文档中包括价值链分析，并于6月30日之前准备完毕）。 . 我们将在本次webinar中与您共同探讨价值链分析应涵盖的深度，以满足中国转让定价的合规要求。另外我们还将通过实际案例分析深入讨论在价值链分析中跨国企业应披露和准备的相应支持性文件。. 本次 w ebinar 焦点内容： . 中国有两种不同的价值链分析方法吗？全球价值链分析和中国具体价值链分析？. 为什么价值链分析对于满足中国国税出台的转让定价新规至关重要？. 是否需要对价值链分析方法做出适当调整来适用于中国特色的转让定价具体情况？ 例如如何处理地域特殊优势问题和新近加入DEMPEP职能下的‘P’职能？. 如何使用价值链分析来协调向中国税务报送的不同转让定价文档：即主文档，本地文件，国别报告和企业年度关联业务往来报告表。. 对中国税务当局的价值链分析合规要求都有那些可能的解读？

Although, the arm’s length principle in essence still is the driving force for analyzing intercompany transactions, how we apply that has changed in important ways. We are now required to follow a holistic approach in the form of Value Chain Analysis (VCA) for the multinational group before we could firmly say what arm’s profits each entity in the group should be earning.

Tax administrations and international economic organizations have reached consensus for implementing international measures that will promote tax transparency amongst the business community.
In this sense, OECD’s BEPS Action Plan 13 addresses ‘Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting’.

This webinar is presented in Spanish language.
Tax administrations and international economic organizations have reached consensus for implementing international measures that will promote tax transparency amongst the business community.

A readiness check on whether your Romanian and Hungarian subsidiaries are fulfilling the local transfer pricing requirements
Transfer pricing is a hot subject for companies operating in Romania and in Hungary. This is because the local tax authorities are focusing more on this topic, with the number of transfer pricing audits increasing significantly in the last few years.

A readiness check on whether your Romanian subsidiary is fulfilling the local transfer pricing requirements.
Transfer pricing is a hot subject for companies operating in Romania.

As G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, full tax transparency is the new norm. The global tax and transfer pricing (“TP”) compliance has become more strict and complex due to new documentation requirements.

A simplified guide to increasing your chances of survival in battles with tax authorities.
Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception.

Value Chain Analysis has become a burning topic for discussion for many after the publication of the final report on BEPS Action Plan 13 and subsequent notifications by governments (especially the Chinese government) on the extent of information to be included in such analysis. Due to lack of consistent and clear guidance on what triggers the need for a value chain analysis, what a value chain analysis should entail, how the value chain analysis will be used by tax authorities around the globe etc.

A total of 44 countries, are participating in the BEPS project on an equal footing. Indonesia has introduced requirements with an aggressive timetable and detail beyond that outlined in Action plan 13.

In this webinar we will share practical insights with you on how to avoid disputes and/or prepare for audits from tax authorities by filling up the gaps that may be existing in the information presented via the CbC Report, TP masterfiles and local country files, corporate tax return and corporate governance policies.
The webinar will consider the following: .

The current US tax reform proposals include the House Republican Tax Reform Blueprint (HRTRB) released in June 2016 and President-elect Trump’s tax proposals that have undergone various refinements over the course of the presidential campaign. While both of these proposals include changes to the taxation of individuals, estates and businesses, the focus of this webinar will be on the proposed changes to the taxation of businesses including those with international operations.

An appropriate presentation of a multinationals’ own value chain will provide for a thorough objective starting point and assist during subsequent tax and TP audit related discussion(s) with tax authorities. Furthermore it provides assistance during advanced discussions relating to substance, significant (people) functions and anchor points with respect to value creation and intangibles.

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 experienced tax professionals in MNEs to be in a better theoretical and practical position to handle and assess a value chain analysis.
During this webinar the following highlights and aspects of using the value chain analysis approach will be addressed:.

The webinar will consider:
How a value chain analysis will fully align the corporate governance framework, operating model and the tax/ TP structure of a MNE..

During this webinar the highlights addressed will be the following:
Current tax policies and Update on BEPS Project of the OECD

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:.

TPA Global is pleased to present to you an informative webinar recording, 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.

Base erosion and profit shifting (BEPS) is a tax avoidance strategy used by multinational companies, wherein profits are shifted from jurisdictions that have high taxes (such as the United States and many Western European countries) to jurisdictions that have low (or no) taxes (so-called tax havens). The term is used in a project headed by the OECD which produced detailed reports in September 2014 in response to seven actions agreed previously.

Transfer pricing is the setting of the price for goods and services sold between controlled (or related) legal entities within an enterprise. For example, if a subsidiary company sells goods to a parent company, the cost of those goods paid by the parent to the subsidiary is the transfer price.

Most rules provide standards for when unrelated party prices, transactions, profitability or other items are considered sufficiently comparable in testing related party items. Such standards typically require that data used in comparisons be reliable and that the means used to compare produce a reliable result.

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?.

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;.

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;.

The recorded webinar will focus 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;.

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 webinar addresses the following:
- 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?.

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 Global provides 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.

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.

Transfer pricing in India has also seen humongous amount of litigation in the area of Comparability Analysis, risk related issues, Arm’s Length Range, TP Adjustment, Location Savings, Intangibles, R&D activities, financial transactions and Intra-group services.
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.

As tax administrations and international economic organizations 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. For example, the implementation of Action plan 13.

With the finalization of Action 13 of BEPS on October 05, 2015, CbC reporting will become a requirement, thereby driving TP compliance costs for MNEs upwards by 25%. Apart from maintaining four layers of TP documentation as required under BEPS, MNEs with operations spread around the globe are constantly faced with a range of varying tax and TP compliance requirements issued in different jurisdictions.

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 will consider the following:.

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:
a global Masterfile for transfer pricing.

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.

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.

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.

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.

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.

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?
This recording will address the following:.

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.
This web event recording addresses the following topics:.

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.

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.

A considerable amount of discussion is generated regarding the implications of a purchase price allocation for transfer pricing purposes. As such this third web event will address the following question: Can you leverage from a purchase price allocation for transfer pricing purposes?
Following an acquisition the purchase price paid must be allocated to all identifiable assets and liabilities assumed, following a set of accounting rules outlined within IFRS 3 and IAS 38.

近年来，伴随着中国在世界经济中扮演的重要角色，外国企业与中国关联企业间的交易越来越多，包括向关联方提供产品或服务、无形资产的特许使用及贷款等。中国 税法规定了转让定价、资本弱化、受控外国公司及一般反避税等规则。此外，中国有19个税种。因此，与中国关联企业的交易比与其他许多国家相同的交易要复杂 的多。了解相关的规则与制度，并遵从其规定，可有利与中国关联企业的交易顺利进行。
为协助跨国公司解决转让定价风险，并避免双重征税，本次网络研讨会旨在从中国税法和转让定价的角度，揭示关联交易定价的税务影响。. 次网络研讨会将讲述以下内容：. - 跨境（出/入）关联交易涉及的相关中国税种. - 跨境（出/入）关联交易定价的中国税务影响. 通过本次网络会议，您能够：. - 更好地了解和理解与中国公司发生关联交易时适用的中国税种与税率。

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.