The finalization of the OECD BEPS guidance in relation to transfer pricing documentation and Country by Country Reporting (“CbCR”) has a profound impact to your approach to supporting your intercompany transactions around the world.
At the same time, on going discussions are getting more intense around new rules on where tax should be paid ("nexus" rules) and on what portion of profits should multinationals be taxed ("profit allocation" rules), on the basis of a "Unified Approach" on the so called Pillar One of the Inclusive Framework of the OECD. This will make it a priority for multinationals to evidence the conduct of a sustained and significant business in places where they operate but most importantly where they may not have a physical presence since they can still be taxed in such jurisdictions.
Progress is also made on the so called Pillar Two, which aims to address remaining BEPS issues, the tax challenges arising from digitalization of the economy and to ensure that international businesses pay a minimum level of tax.
Our team will work with you to ensure that your international financial position is effectively managed and your fiscal risk covered. Together, we can put your organization in the best possible position to take advantage of the benefits of globalization and international structuring by
improving your operational and financial performance based on a long-term view of sustainable growth
providing advice and assistance in preparing transfer pricing documentation in accordance to Greek or foreign legislation to protect your organization from high re-assessments and administrative penalties
supporting you in resolving disputes with the tax authorities and in concluding advance pricing arrangements in jurisdictions providing for such framework
With over 3,100 transfer pricing professionals deployed in more than 90 countries, we’re well positioned to advise you on developing compliant, tax-efficient structures that help advance your business goals.