Transfer Pricing, OECD & BEPS

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Transfer Pricing, OECD & BEPS

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Transfer Pricing, OECD & BEPS

Implementing the New Transfer Pricing Terminologies

  • Identifying “commercial relations” and “financial relations”
  • Ascertaining “economically relevant characteristics”
  • Fragmenting “highly integrated functions”
  • Avoiding “moral hazards” in transfer pricing
  • Understanding the scope of “risk-return” tradeoffs
  • Combining “guarantee fees” with “high value” consulting services
  • The future of “location savings,” “workforce assemblage,” and “synergies”
  • Coping with “thick capitalization” issues

Transfer Pricing Mechanisms under the BEPS Regime

  • “Profit shifting” and “base erosion” – the essence of transfer pricing
  • The role of public accountants, cost accountants, economists, and lawyers in transfer pricing
  • Two-sided and one-sided transfer pricing alternative mechanisms
  • Disconnect between location of value created and profits
  • Restoring the full effects of international standards
  • Response to aggressive tax planning

Breadth and Scope of the Intangible Transfer Pricing Provisions

  • Defining the definition, character, and attributes of intangibles
  • The characterization of “hard-to-value” intangibles
  • The role of the OECD provisions in ascertaining intangibles
  • The renewed importance of the legal ownership/contractual arrangement definition
  • Remuneration for developers and exploiters of the intangible

How the Digital Economy Impacts the Transfer Pricing Regime

  • Back to the future – the 1998 ministerial conference
  • Impact of the BEPS Action 1’s final BEPS report
  • The “neutrality” requirement between electronic products and non-electronic products
  • Impact on VAT and other consumption taxes on electronic commerce
  • How international tax arrangements impact electronic commerce

Being Prepared: Meeting the Documentation Requirements

  • Complying with inconsistent documentation requirement
  • Meeting the “contemporaneous documentation” requirements
  • Master file and local file: the OECD adopts the EU approach
  • Applying the reporting template by jurisdiction and by constituent entity
  • The transfer pricing report and its timing requirements
  • Coping with diverse language translation issues
  • PATA and country-by-country documentation

Transfer Pricing Audit Strategies

  • Preparing your “best method” audit defense
  • Defending your choice of transfer pricing method to the authorities
  • Factors that will trigger a tax audit
  • Types of information requests and taxpayer response strategies
  • Responding to draft proposed adjustments
  • Litigation preparation