On 18 December 2020, the “OECD Guidance on transfer pricing implications of the COVID-19 pandemic” was published with the aim of aiding tax authorities and taxpayers in dealing with complexities resulting from COVID-19. In Singapore, the IRAS released the “Support Measures and Tax Guidance - Transfer Pricing” which equally provides practical guidance for local taxpayers to consider when preparing upcoming transfer pricing documentations.
This webinar aims to consider the issues and opportunities emerging from the OECD Guidance and to address business concerns of organisations from a transfer pricing angle.
The transfer pricing environment has never been more challenging. Globalized trade and operating models and the transfer pricing policies developed alongside them are increasingly buffeted by technology advances, geopolitical developments, regulatory change, increased transparency and now deep economic uncertainty and tax hungry governments. Against this backdrop, companies need, more than ever before:
Our experienced team of transfer pricing practitioners, drawn from all corners of the world, can help you navigate the complexities, reduce your risks and maximise your opportunities in this complex and uncertain world.
We provide practical and tailor made transfer pricing solutions to your business life cycle needs within the national, regional and international space in the areas of:
As businesses evolve, their transfer pricing policies need to keep pace. We work with companies to ensure that their transfer pricing policies align profit recognition with value contribution. Our teams are expert in:
On 11 February 2020, the OECD issued the long awaited final version of the Financial Transactions paper . The paper reflects a consensus position, for the first time, with respect to the treatment and pricing of intercompany financial transactions. The document, amongst other things, evaluates the approach to thin capitalisation and the pricing of debt, cashpooling, hedging and intercompany guarantees.
With ever more focus by local and regional tax authorities on financial transactions it is important that transfer pricing policies are coordinated and aligned across jurisdictions. Our dedicated team of Financial Services and Financial Transactions specialists are here to help you design, implement, defend and document transfer pricing policies for Financial Transactions and Treasury activities.
A policy is only as good as its execution. It’s the last mile that makes all the difference to managing your transfer pricing risk.
While the outcome of transfer pricing compliance is principally the responsibility of the tax function, execution of intercompany transactions often spreads across several other functions such as controllership, accounting, IT, legal, trade and customs.
Not getting it right can lead to costly financial consequences in the form of transfer pricing adjustments, indirect taxes, customs duties and time-consuming audit defence work.
A clear governance process with responsibilities understood across business functions forms the backbone of good TP execution. This can then support further automation benefits, allowing a less manual and more accurate and efficient process in price setting, monitoring and adjustment.
Recognising that TP execution is more than just a tax function’s responsibility, our team comprises experts not only in transfer pricing but also in customs and trade, indirect tax, accounting, management, IT and change consulting. Our team can help you:
A key feature of the rapidly evolving tax landscape is the drive for increased transparency and reporting and the concomitant increase in taxpayer scrutiny and controversies. Transfer pricing documentation is therefore not only a compliance requirement in most markets, but also represents the first line of audit defence. Accordingly, best in class companies adopt documentation with more than just a compliance mindset and consider it as a central plank in their strategic tax risk management strategy.
Our experts can help you to assess your compliance and strategic needs holistically, and develop a ‘fit for purpose’ approach to managing your transfer pricing risks in a cost effective manner. Our work includes:
Our services are delivered using a technology enabled approach with leading-edge tools to drive efficiency and improve quality through rich and granular data analysis and a coordinated workflow, document and data management system.
With more and more countries introducing formal transfer pricing documentation requirements and against a backdrop of increased transparency, transfer pricing audits and tax controversies are on the increase. As tax authorities become more sophisticated and data driven, and as their expectations of taxpayers grow, so audits are becoming ever more thorough.
This new environment therefore requires multinational corporations to take proactive, coordinated steps to understand their transfer pricing arrangements and documentation requirements, to have a clear view on how tax authority engagement should be managed and to maintain “audit ready” evidence to support the positions they take. Our Tax Controversy and Dispute Resolution experts are ready to help you:
As businesses grapple with the fallout from COVID-19, the measures being taken on can have far reaching implications for transfer pricing (TP). With little published guidance available and as we await the OECD to response, how should tax departments react?
Our video series titled Transfer Pricing in the New Normal provides interesting insights, touching on refinancing and the pricing of debt, how to accommodate losses within the transfer pricing policy, managing variances, TP adjustments, Advance Pricing Agreements and documentation.