Transfer Pricing based on HFM and TPH (Transfer Pricing for Hyperion) Matthew Prior & Neil Weller AMOSCA
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1 Transfer Pricing based on HFM and TPH (Transfer Pricing for Hyperion) Matthew Prior & Neil Weller AMOSCA
2 Agenda Transfer Pricing» Background and context Introducing TPH (Transfer Pricing for Hyperion)» An overview» Demo» Features and benefits
3 Transfer Pricing Background and Context
4 Transfer Pricing In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions between enterprises under common ownership or control.
5 Fundamental Concepts The cornerstone of transfer pricing is the arm s length principle The amount of profit on transactions between connected parties should for tax purposes be the amount of profit that would have arisen if the same transactions had been executed by unconnected parties This principle is enshrined in OECD guidelines and followed by the tax authorities of most OECD members Many countries require MNE s (Multi National Enterprises) to maintain documentation to demonstrate inter-company transactions are at arm s length» Typically requires extensive analysis and benchmarking of comparables Advance Pricing Agreements can be negotiated with some tax authorities
6 How to determine arm s length pricing Five methods for determining arms length pricing are recognised in the OECD guidelines and US transfer pricing regulations: Comparable uncontrolled price - CUP» Price of comparable transaction between independent parties Resale price method - resale minus» Purchase price of goods for sales and distribution entities Cost plus» Sale price of goods for manufacturers, pricing of intra-group services Transactional Net Margin TNMM» Compare with the return earned by comparable independent enterprise Comparable profits CPM» As TNMM Profit split PSM» Not a recognised method but often asserted or resorted to in disputes
7 Why transfer pricing is important
8 BEPS (Base Erosion & Profit Shifting) The Inclusive Framework on BEPS brings together over 100 countries and jurisdictions to collaborate on the implementation of the OECD/ G20 Base Erosion and Profit Shifting (BEPS) Package. BEPS refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity. Although some of the schemes used are illegal, most are not. This undermines the fairness and integrity of tax systems because businesses that operate across borders can use BEPS to gain a competitive advantage over enterprises that operate at a domestic level.
9 BEPS Action 13 CbC Reporting
10 In the last month alone
11 Introducing Transfer Pricing for Hyperion
12 HFM and TPH HFM the world s best aggregation and reporting engine» Financial logic» Development capabilities practically unlimited» Range of reporting options and capabilities» Integration utilities» Availability of skills
13 HFM and TPH TPH = Transfer Pricing for HFM» Graphical tax calculator» Transfer pricing rules editor» Process automation» Audit trail» HFM transfer pricing application Developed by PebbleAge, Swiss specialists in corporate tax and finance software solutions» Operational Transfer Pricing» Financial Agility» Hyperion Financial Management» Strategic Planning
14 HFM & TPH
15 System landscape of TPH
16
17 Tax calculations
18 Additional functionality added to HFM Drag & drop graphical HFM formula editor
19 Rules repository
20 Process Design
21 Process automation and co-ordination
22 Reports SKU analysis
23 Reports SKU analysis
24 Reports
25 Reports
26 Reports P&L Segmentation Analysis per IP Owner & per Supplier
27 Reports P&L Summary for All Legal Entities
28 Transfer Pricing Adjustment Validation
29 Generate profit split transactions
30 Audit Trail
31 Benefits of TPH Monitoring» Monitoring & Co-ordination» Integrated Audit Trail» Tax & Finance data aligned Optimise Tax Return» Proactive Transfer Pricing management» Full financial simulations prior to execution» Measure the bottoem line impact Save operational costs» Full automation of manual procedures» Avoidance of spreadsheet nightmare» Reduce consulting and audit fees
32 Features & Benefits of TPH
33 Thank you
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