IBFD Course Programme Transfer Pricing and Substance Masterclass
|
|
- Phoebe Waters
- 5 years ago
- Views:
Transcription
1 IBFD Course Programme Transfer Pricing and Substance Masterclass
2 Overview and Learning Objectives The OECD BEPS project focuses on two items: substance and transparency. This is reflected in the reports published by the OECD on, inter alia, services, intangibles, intra-group financing and country-bycountry (CbC) reporting. The BEPS reports entail changes for day-to-day business operations. Businesses have already taken action (in some cases, urgent action) both to comply with new requirements and to consider the ways in which they do business in different countries. Monitoring and taking, additional actions may be needed in The masterclass will address questions such as how create value translates into a price or transfer pricing methodology, how to approach a value chain analysis and how to get the information related to CbC reporting out of an organization. This advanced-level, interactive masterclass consists of case studies and sharing best practices. It is designed for participants who already have knowledge of transfer pricing and want to gain more in-depth understanding of the implications of BEPS in their day-to-day practice. Participants will receive a roadmap on the changes that each of the BEPS reports on transfer pricing brings and how these reports are interrelated. The objective of the masterclass is to introduce the participants to changes flowing from the OECD BEPS reports. The masterclass is designed to provide an understanding of the guidelines laid down in the BEPS reports. This will be done by means of case studies focusing e.g. on specific transactions. Following a brief introduction to the individual topics, each session is complemented by a case study applying the principles in practice. In order to ensure the interactive nature of the masterclass, the number of participants is limited to 32. Prior to the event, participants will be given access to an online platform which provides them with additional reading material and supplementary material (e.g. legal documentation, case law and related articles/literature. Field of Study Taxes Who Should Attend? The course is suitable for transfer pricing advisers, lawyers, accountants, in-house transfer pricing managers, controllers and finance staff. Course Level and Prerequisites This is an advanced-level course. Participants taking this course will be expected to have a good understanding of transfer pricing principles. 2
3 Day Registration Welcome and IBFD Overview Case Study: Applying Arm s Length Principle and Transfer Pricing Methods Actions 8-10 Value chain analysis Identifying commercial and financial relations Comparability factors, i.a.: functional analysis risks, changes to section D of chapter I of the OECD Guidelines Non-recognition of transactions Interaction Action 13 of BEPS Case Study: Applying Arm s Length Principle and Transfer Pricing Methods (continued) Case Study: Intangibles Link with chapters I-III of the OECD Guidelines and Actions 8-10 Identifying intangibles Ownership of intangibles Allocating intangible returns Link with Action Case Study: Intangibles continued) 3
4 Day Case Study: Services Link with chapters I-III of the OECD Guidelines and Actions 8-10 Identifying services Arm s length remuneration Low value adding intra-group services Cost sharing arrangements and link with Actions Case Study: Services (continued) Case Study: Intra-Group Financing Introduction Actions 8-10 Link with Action 2 Link with Action 4 Link with Action Case Study: Intra-Group Financing (continued) 4
5 Day Compliance Action 13 Master and local file Financial compliance Workshop including themes like education/communication and technology Sharing best practices Compliance (continued) Case Study: Dispute Resolution Action 14 Link with Action 5 EU developments Case Study: Dispute Resolution (continued) 5
IBFD Course Programme Transfer Pricing: Financial Services Industry Masterclass
IBFD Course Programme Transfer Pricing: Financial Services Industry Overview and Learning Objectives Digitalization has changed and will continue to change business models. This will impact the global
More informationIBFD Course Programme Principles of Transfer Pricing
IBFD Course Programme Principles of Transfer Pricing Price: 1,300 (US$ 1560) Price for full IBFD Members: 1,040 (US$ 1,248) Early Bird Discount: A 30% discount will be applied to registrations for this
More informationIBFD Course Programme Principles of Transfer Pricing
IBFD Course Programme Principles of Transfer Pricing Overview and Learning Objectives On 5 October 2015, the OECD published its reports addressing base erosion and profit shifting (BEPS). This new guidance
More informationIBFD Course Programme International Tax Planning after BEPS and the MLI
IBFD Course Programme International Tax Planning after BEPS and the MLI Summary Recent developments such as the BEPS project and the Multilateral Instrument in international taxation, but also unilateral
More informationPrinciples of Transfer Pricing
Summary This intermediate-level five-day course introduces participants to transfer pricing principles and methodologies and then covers the application of these principles and methodologies to specific
More informationIBFD Course Programme Transfer Pricing: Compliance and Audit Management in Southeast Asia
IBFD Course Programme Transfer Pricing: Compliance and Audit Management in Southeast Asia Summary This course will provide you with the best practices for implementing transfer pricing documentation requirements
More informationIBFD Course Programme Offshore Entities Past, Present and Future
IBFD Course Programme Offshore Entities Past, Present and Future Summary Offshore tax evasion is a serious problem for jurisdictions all over the world Source: OECD report for the G20 meeting in Sydney
More informationIBFD Course Programme International Tax Aspects of Permanent Establishments
IBFD Course Programme International Tax Aspects of Permanent Establishments Overview and Learning Objectives This tax course is designed to provide participants with an in-depth analysis of the concept
More informationIBFD Course Programme Principles of Transfer Pricing
IBFD Course Programme Principles of Transfer Pricing Price: 1,875 (US$ 2,415) Price for full IBFD Members: 1,500 (US$ 1,932) Early Bird Discount: A 30% discount will be applied to registrations for this
More informationIBFD Course Programme Current Issues in International Tax Planning
IBFD Course Programme Current Issues in International Tax Planning Summary This intermediate-level course provides participants with an in-depth understanding of the current discussions relating to international
More informationPrinciples of International Tax Planning
Overview and Learning Objectives This course is aimed at analysing the fundamentals of international tax planning in a structured and consistent manner, deepening the knowledge of tax planning techniques
More informationPrinciples of International Taxation
Overview and Learning Objectives This tax course is designed to provide participants with the essentials of international taxation. The first three days are dedicated to the fundamental concepts relevant
More informationIBFD Course Programme Current Issues in International Tax Planning
IBFD Course Programme Current Issues in International Tax Planning Amsterdam, 14 16 June 2017 Summary This intermediate-level course provides participants with an in-depth understanding of the current
More informationIBFD Course Programme BEPS Country Implementation
IBFD Course Programme BEPS Country Implementation Summary On 5 October 2015, the OECD published the final reports of its 15-point base erosion and profit shifting (BEPS) project. A bit more than a year
More informationIBFD Course Programme Principles of International Taxation
IBFD Course Programme Principles of International Taxation Need a good base to start your career in international tax? This course will provide the essential knowledge you need and give you the confidence
More informationInternational Taxation of Oil and Gas and Other Mining Activities
Overview and Learning Objectives This course is designed to provide participants with in-depth analyses of international taxation issues related to oil and gas and other mining activities. It starts with
More informationIBFD Course Programme European Value Added Tax Selected Issues
IBFD Course Programme European Value Added Tax Selected Issues Overview and Learning Objectives This course covers selected value added tax (VAT) issues in the European Union, including current developments,
More informationIBFD Course Programme Global VAT
IBFD Course Programme Global VAT Summary This four-day intermediate-level course on global VAT/GST offers participants the opportunity to gain a basic understanding of the principles of VAT and GST around
More informationTax Planning in the Middle East
Overview and Learning Objectives This three-day intermediate-level course concentrates on a number of common international tax planning scenarios in the Middle East region. It examines the widely used
More informationIBFD Course Programme Practical Aspects of Tax Treaties
IBFD Course Programme Practical Aspects of Tax Treaties Overview and Learning Objectives With increasing cross-border investments, taxpayers may be confronted with double taxation. For over a century,
More informationSpain. Transfer Pricing Country Profile. Updated October The Arm s Length Principle
Spain Transfer Pricing Country Profile Updated October 2017 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle? 2 What
More informationUruguay. Transfer Pricing Country Profile. Updated October The Arm s Length Principle
Uruguay Transfer Pricing Country Profile Updated October 2017 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle? 2
More informationDeloitte School of Tax International Tax and Transfer Pricing Workshop
Deloitte School of Tax International Tax and Transfer Pricing Workshop Introduction International tax and transfer pricing are primary focus areas for revenue authorities globally. The upsurge of foreign
More informationOn October , the OECD released its final report on
New TP documentation rules: update and CbCR example Maik Heggmair and Tobias Faltlhauser of WTS summarise the new transfer pricing (TP) documentation rules to be implemented in Germany and provide an example
More informationtransfer pricing documentation
Mai Nomura Summary Headline on Verdana CbC reporting Bold and transfer pricing documentation Mai Nomura 24 October, 2017 New transfer pricing compliance requirements in Hungary: Country-by-Country Reporting
More informationPrinciples of International Taxation
Overview and Learning Objectives This course is designed to provide participants with the essentials of international taxation. The first three days are dedicated to the fundamental concepts relevant to
More informationIBFD Course Programme Global VAT
IBFD Course Programme Summary This four-day intermediate-level course on global VAT/GST offers participants the opportunity to gain a basic understanding of the principles of VAT and GST around the globe.
More informationUS Corporate Taxation
Overview and Learning Objectives This course provides participants with an essential overview and comprehensive understanding of the complex US tax system, with particular emphasis on international aspects.
More informationHeadline Verdana Bold International Tax matters ICPAU Tax Seminar, Hotel Africana November, 2017
Headline Verdana Bold International Tax matters ICPAU Tax Seminar, Hotel Africana November, 2017 Contents Related party transactions 3 URA practice on international tax 14 OCED Action Plan on BEPS 30 2017
More informationIBFD Course Programme Introduction to GCC VAT
IBFD Course Programme Introduction to GCC VAT Dubai, UAE 3 5 March 2019 Price: 1,500 (US$ 1,880) Price for full IBFD Members: 1,200 (US$ 1,504) Early Bird Discount: A 30% discount will be applied to registrations
More informationTransfer Pricing Country Summary The Netherlands
Page 1 of 6 Transfer Pricing Country Summary The Netherlands June 2018 Page 2 of 6 Legislation Existence of Transfer Pricing Laws/Guidelines On 11 May 2018 the Dutch Ministry of Finance published a new
More informationIBFD International Tax Training 2018
IBFD, Your Portal to Cross-Border Tax Expertise www.ibfd.org IBFD International Tax Training 2018 Designed to meet your professional needs Tax Courses Tailored Tax Courses Webinars Online Tax Courses 80
More informationIBFD Course Programme Tax Planning in Africa and the Middle East
IBFD Course Programme Tax Planning in Africa and the Middle East Gain in-depth knowledge on a number of common international tax planning scenarios in Africa and the Middle East. You can now attend this
More informationOverview of OECD Action Plan on Base Erosion and Profit Shifting (BEPS)
Overview of OECD Action Plan on Base Erosion and Profit Shifting (BEPS) Monia Naoum, IBFD Research Associate Emily Muyaa, IBFD Research Associate 18 June 2015 1 Introduction: Globalization and its impact
More informationTransfer Pricing Documentation Requirements
Articles China (People's Rep.) Andreas Riedl and Thomas Steinbach* Transfer Pricing Documentation Requirements The authors compare the documentation standard arising from the BEPS Action 13 Final Report
More informationUnited States. Transfer Pricing Country Profile. Updated October The Arm s Length Principle
United States Transfer Pricing Country Profile Updated October 2017 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle?
More informationHong Kong SAR Government s Roadmap following the outcomes of the BEPS Consultation
News Flash Transfer Pricing Hong Kong SAR Government s Roadmap following the outcomes of the BEPS Consultation August 2017 In brief On 31 July 2017, the Hong Kong SAR Government (the Government) released
More information1. New decree on transfer-pricing documentation requirements
THE NETHERLANDS 1. New decree on transfer-pricing documentation requirements 1.1. Introduction As from 1 January 2016, Netherlands-resident entities (and Netherlands permanent establishments) that are
More informationPCT WBG IMF OECD. The Platform for Collaboration on Tax (PCT) The Platform for Collaboration on Tax (PCT) Workplan: PCT 14 Actions
The Platform for Collaboration on Tax (PCT) The (PCT) Strengthening Tax Capacity in Developing Countries: Inter-agency ECOSOC Special Meeting on International Cooperation in Tax Matters New York, 18 May
More informationPost-BEPS application of the arm s length principle: India charts a new course
Post-BEPS application of the arm s length principle: India charts a new course India Tax Insights Rajendra Nayak Partner Tax & Regulatory Services, EY India An updated version of the United Nations Transfer
More informationLEARNING OBJECTIVES TRANSFER PRICING DOCUMENTATION. THE ROLE OF TPD Showing Compliance. Fundamentals of Transfer Pricing Documentation
UN-ATAF Workshop on Transfer Pricing Administrative Aspects and Recent Developments Ezulwini, Swaziland 4-8 December 2017 LEARNING OBJECTIVES Understanding and Reviewing Transfer Pricing Documentation
More informationOECD releases discussion draft on transfer pricing documentation and
Tax Policy Bulletin Tax Insights from Transfer Pricing OECD releases discussion draft on transfer pricing documentation and country-by-country reporting 31 January, 2014 In brief Multinational enterprises
More informationRussian Federation. Transfer Pricing Country Profile. Updated October The Arm s Length Principle
Russian Federation Transfer Pricing Country Profile Updated October 2017 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle?
More information15445/17 AS/AR/mpd 1 DG G 2B
Council of the European Union Brussels, 5 December 2017 (OR. en) 15445/17 FISC 346 ECOFIN 1092 OUTCOME OF PROCEEDINGS From: General Secretariat of the Council To: Delegations No. prev. doc.: 15175/17 Subject:
More informationBEPS Country-by-Country Reporting Rules and New Documentation Requirements
BEPS Country-by-Country Reporting Rules and New Documentation Requirements, EY LLP, Couzin Taylor LLP 67 th Annual Tax Conference 67e Conférence fiscale annuelle 2015 Agenda 1. The BEPS project: Action
More informationThe Addis Ababa Action Agenda of the Third. United Nations Capacity Development Programme on International Tax Cooperation
United Nations Capacity Development Programme on International Tax Cooperation Contents Link to the Addis Ababa Action Agenda and the 2030 Agenda for Sustainable Development 1 Mandate 2 Relationship with
More informationOECD/G20 Base Erosion and Profit Shifting Project
OECD/G20 Base Erosion and Profit Shifting Project Action 13: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting Country-by-Country Report Instructions Manual 24 June 2015 Page
More informationGlobal Transfer Pricing Review
GLOBAL TRANSFER PRICING SERVICES Global Transfer Pricing Review Czech Netherlands Republic kpmg.com/gtps TAX 2 Global Transfer Pricing Review Netherlands KPMG observation The Dutch Tax Authorities intend
More informationIsrael. Transfer Pricing Country Profile. Updated February The Arm s Length Principle
Israel Transfer Pricing Country Profile Updated February 2018 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle? 2
More informationOur commentary focuses on five main issues. Supplementary comments relating to specific paragraphs or issues are provided in the appendix.
Comments on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles by the Confederation of Netherlands Industry and Employers (VNO-NCW) We are pleased to see the significant progress which
More informationSOUTH AFRICA GLOBAL GUIDE TO M&A TAX: 2017 EDITION
SOUTH AFRICA 1 SOUTH AFRICA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? In the 2016 Budget Review, tax avoidance
More informationEBIT
EBIT www.ebit-businesstax.com Comments on the Scoping of the future revision of Chapter VII (Intra group services) of the OECD s Transfer Pricing Guidelines EBIT s Members at the time of writing this submission:
More informationIrish Government announces Budget 2016 and publishes update on international tax strategy
16 October 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Irish
More informationATO Tax Risk Management Workshop Plenary session
ATO Tax Risk Management Workshop Plenary session April / May 2015 Reinventing the ATO We are improving the client experience Make it easier to comply for those doing the right thing We are future focussed
More informationPractical Implications of BEPS
www.pwc.com/il Practical Implications of BEPS Vered Kirshner, Tax Partner, PwC Israel Ben Blumenfeld, Tax and Transfer Pricing Senior Manager, PwC Israel Aim of BEPS Action plan backed by the OECD and
More informationTHE OECD BEPS ACTION PLAN
THE OECD BEPS ACTION PLAN Intangibles and Services Seminar 28-03-2017 INTRODUCTION TO COPENHAGEN ECONOMICS IP Valuation & Transfer Pricing We help our clients by quantifying the economic value of various
More informationTransfer Pricing Country Summary Turkey
Page 1 of 8 Transfer Pricing Country Summary Turkey August 2018 Page 2 of 8 Legislation Existence of Transfer Pricing Laws/Guidelines Formal transfer pricing rules were introduced in Turkey on 21 June
More informationGermany. Transfer Pricing Country Profile. Updated October The Arm s Length Principle
Germany Transfer Pricing Country Profile Updated October 2017 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle? Foreign
More informationthe treatment of external and intra-group borrowing costs in consolidated financial statements of the parent
Capitalisation of borrowing costs in a group situation Hot topics may include Grant Thornton International s analysis of how IFRS should be applied in particular situations. Grant Thornton International
More informationImplementation of Masterfile and Localfile (BEPS Action 13) Georg Berka
Implementation of Masterfile and Localfile (BEPS Action 13) Georg Berka Roadmap BEPS Action 13 in general Content of Masterfile Content of Localfile How Masterfile and Local File can be implemented chapter
More informationTransfer Pricing Country Summary Portugal
Page 1 of 8 Transfer Pricing Country Summary Portugal August 2018 Page 2 of 8 Legislation Existence of Transfer Pricing Laws/Guidelines Provisions regarding transfer pricing matters are incorporated in
More informationTransfer Pricing Country Summary Romania
Page 1 of 8 Transfer Pricing Country Summary Romania June 2018 Page 2 of 8 Legislation Existence of Transfer Pricing Laws/Guidelines Overview General Transfer Pricing rules have been implemented in Romanian
More informationEgypt updates Transfer Pricing Guidelines
Egypt updates Transfer Pricing Guidelines October 2018 In brief On 23 October 2018, the Egyptian Tax Authority ( ETA ) published an update to the Egyptian Transfer Pricing Guidelines ( ETPG ) which were
More informationTPA Global. Top-10 Solutions. tpa-global.com
TPA Global Top-10 Solutions 1 Top Ten TP Specific Solutions - Overview 2 1 Are you in control on tax/tp? TPA offers a solution to MNEs to be in control of their organizational and operational aspects of
More informationEU JOINT TRANSFER PRICING FORUM
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Direct taxation, Tax Coordination, Economic Analysis and Evaluation Company Taxation Initiatives Brussels, June 2013 Taxud/D1/ DOC: JTPF/007/FINAL/2013/EN
More informationProtecting the Tax Base of Developing Countries: An Overview
Papers on Selected Topics in Protecting the Tax Base of Developing Countries Draft Paper No. 1 May 2013 Protecting the Tax Base of Developing Countries: An Overview Hugh J. Ault Professor Emeritus of Tax
More informationIFRS 15 for automotive suppliers
IFRS 15 for automotive suppliers Are you good to go? Application guidance December 2017 Contents Contents Purpose of this document 1 What may change? 2 1 Tender offer phase Nomination fees 4 2 Framework
More informationUN-ATAF Workshop on Transfer Pricing Administrative Aspects and Recent Developments Ezulwini, Swaziland 4-8 December 2017
UN-ATAF Workshop on Transfer Pricing Administrative Aspects and Recent Developments Ezulwini, Swaziland 4-8 December 2017 BACKGROUND NOTE Introduction The United Nations has transitioned from the Millennium
More informationTAX ALERT NEW CIRCULAR N 56/1 56BIS/1 ON THE TAX TREATMENT OF COMPANIES ENGAGED IN INTRA-GROUP FINANCING TRANSACTIONS JANUARY
TAX ALERT NEW CIRCULAR N 56/1 56BIS/1 ON THE TAX TREATMENT OF COMPANIES ENGAGED IN INTRA-GROUP FINANCING TRANSACTIONS JANUARY - 2017 ã2017 I. INTRODUCTION On 27 December 2016, the Luxembourg tax authorities
More informationCyprus Tax News New rules for taxation of intra-group financing arrangements
Cyprus Tax & Legal Services 3 July 2017 Issue 14/2017 Cyprus Tax News New rules for taxation of intra-group financing arrangements On 30 June 2017, the Cyprus Tax Department ( CTD ) issued a Circular with
More informationCyprus Tax Authority issues guidance on revised transfer pricing framework for intra-group financing activities
5 July 2017 Global Tax Alert News from Transfer Pricing Cyprus Tax Authority issues guidance on revised transfer pricing framework for intra-group financing activities EY Global Tax Alert Library Access
More informationIMF Revenue Mobilizations and Development Conference: Session on Business Taxation. Alan Carter (ITD) Washington DC, April 18, 2011
IMF Revenue Mobilizations and Development Conference: Session on Business Taxation Alan Carter (ITD) Washington DC, April 18, 2011 International Business Tax Issues - Why are international tax issues important?
More informationRoundup of Australia s BEPS developments
TaxTalk Insights Global Tax Roundup of Australia s BEPS developments 12 April 2017 In brief Since its presidency of the G20 in 2014, Australia has been at the forefront of efforts to combat tax avoidance
More informationKPMG s general comments on the Discussion Draft are as follows:
KPMG International To Andrew Hickman Head of Transfer Pricing Unit Centre for Tax Policy and Administration OECD From KPMG Date Ref Comments to the OECD: BEPS Action 10 Discussion Draft on the Transfer
More informationBEPS: What does it mean for funds and asset managers?
BEPS: What does it mean for funds and asset managers? Client Seminar Martin Shah René van Eldonk Malcolm Richardson, M&G 10 March 2015 Overview Background to and progress to date of BEPS Action Plan More
More informationOur comments, as set out in this letter, have been referenced with the relevant section in the OECD Discussion Draft.
Mr. Joseph L. Andrus Head of Transfer Pricing Unit OECD Centre for Tax Policy and Administration Email: joe.andrus@oecd.org 18 September 2012 Ref.: DTA/PRJ/PWE/ACH Dear Mr Andrus, Re: OECD Discussion Draft
More informationBase Erosion and Profit Shifting Project and Developing Economies
2015/FMP/WKSP1/021 Session: 6 Base Erosion and Profit Shifting Project and Developing Economies Submitted by: OECD Workshop on Fiscal Management Through Transparency and Reforms Bagac, Philippines 9-10
More informationThough funds are generally exempt from profits tax in Hong
Tax Law: Latest Developments in the Taxation of Hong Kong Asset Managers As Hong Kong proposes new rules to combat base erosion and profit shifting ( BEPS ), asset management groups operating in Hong Kong
More informationNew Zealand. Transfer Pricing Country Profile. Updated October The Arm s Length Principle
New Zealand Transfer Pricing Country Profile Updated October 2017 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle?
More informationBEP-VVA-Gallo GRAZIANO GALLO. Comments on the scoping of the OECD future project on the Transfer Pricing Aspects of Intangibles
BEP-VVA-Gallo Comments on the scoping of the OECD future project on the Transfer Pricing Aspects of Intangibles Milan, 15 September 2010 September 2010 Dear Mr. Owens, as requested in your invitation letter
More informationOECD Publishes Guidance on Transfer Pricing Documentation and Country-by-Country Reporting
17 September 2014 OECD Publishes Guidance on Transfer Pricing Documentation and Country-by-Country Reporting Action 13 On 16 September 2014, the Organization for Economic Co-operation and Development (
More informationWORKING PAPER. Financial Counsellors - ECOFIN preparation Presidency Issues Note on 'Tax Certainty in a Changing Environment'
Brussels, 29 March 2017 WK 3787/2017 INIT LIMITE ECOFIN WORKING PAPER This is a paper intended for a specific community of recipients. Handling and further distribution are under the sole responsibility
More informationAnnual International Bar Association Conference Sydney, Australia. Recent Developments in International Taxation. Republic of Cyprus
Annual International Bar Association Conference 2017 Sydney, Australia Recent Developments in International Taxation Republic of Cyprus Venetia Argyropoulou European University of Cyprus v.argyropoulou@euc.ac.cy
More informationChina s SAT Issues Draft Guidance on Transfer Pricing Rules and BEPS Initiatives
China s SAT Issues Draft Guidance on Transfer Pricing Rules and BEPS Initiatives China s State Administration of Taxation (SAT) on 17 September released a discussion draft of Special Tax Adjustment Implementation
More informationTAX POLICY. assets 1. A description of how Sanofi evaluates these is detailed below.
TAX POLICY G4 indicators : G4-DMA,G4-EC1 I. THE CHALLENGE Our objective is to ensure that tax is paid and tax returns are filed on time in each jurisdiction in compliance with the governing laws and rules.
More informationLUXEMBOURG GLOBAL GUIDE TO M&A TAX: 2018 EDITION
LUXEMBOURG 1 LUXEMBOURG INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Corporate income tax ( CIT ) rate The CIT rate
More information- Simplification rule for pure intermediary companies : remuneration
Theme Source of law Object / Date of application PAST CHANGES Impact / Comments 1. Transfer Pricing Article 56 of the Luxembourg Income Tax Law (LIR) and paragraph 171 Abgabenordnung Introduction of the
More informationMOVING AFRICA BEYOND AID THROUGH TAX REVENUE MOBILISATION OUTCOMES STATEMENT October 2018
5 th ATAF GENERAL ASSEMBLY CONFERENCE MOVING AFRICA BEYOND AID THROUGH TAX REVENUE MOBILISATION OUTCOMES STATEMENT 23-25 October 2018 Executive Summary 1. This significant event comprised a series of related
More informationAUDIT AND RISK ASSESSMENT
UN-ATAF Workshop on Transfer Pricing Administrative Aspects and Recent Developments Ezulwini, Swaziland 4-8 December 2017 INTRODUCTION TO AUDITS AND Importance of Risk Assessment AUDIT AND Monday, 4 December
More informationLuxembourg transfer pricing legislation at a glance
2017 EY TAX Alert Luxembourg Luxembourg transfer pricing legislation at a glance Executive summary The law of 23 December 2016 on the budget for the year 2017 ( Budget Law ) has introduced a new article
More informationTransfer Pricing Country Summary Sweden
Page 1 of 7 Transfer Pricing Country Summary Sweden 26 June 2018 Page 2 of 7 Legislation Existence of Transfer Pricing Laws/Guidelines Chapter 14, Section 19-20 of the Swedish Income Tax Act contains the
More informationMr. Joe Andrus Head of Transfer Pricing Unit Centre for Tax Policy and Administration OECD 2, rue Andre Pascal Paris France.
PricewaterhouseCoopers Aktiengesellschaft Wirtschaftsprüfungsgesellschaft Mr. Joe Andrus Head of Transfer Pricing Unit Centre for Tax Policy and Administration OECD 2, rue Andre Pascal 75775 Paris France
More informationThe OECD report on base erosion and profit shifting (BEPS) and EU measures against aggressive tax planning and tax fraud
The OECD report on base erosion and profit shifting (BEPS) and EU measures against aggressive tax planning and tax fraud Pere M. Pons New York, May 6 th, 2013 Agenda I. Background II. Key pressure areas
More informationCopenhagen Economics welcomes the opportunity to comment on the OECD s Discussion Draft on BEPS 8-10, Financial transactions, issued on 3 July 2018.
Copenhagen Economics Kungsgatan 38, 5tr 111 35 Stockholm Sweden Tax Treaties, Transfer Pricing and Financial Transactions Division OECD - Centre for Tax Policy and Administration 2, Rue André Pascal 75775
More informationOECD GUIDELINES ON INSURER GOVERNANCE
OECD GUIDELINES ON INSURER GOVERNANCE Edition 2017 OECD Guidelines on Insurer Governance 2017 Edition FOREWORD Foreword As financial institutions whose business is the acceptance and management of risk,
More informationRussian Federation. Transfer Pricing Country Profile. Updated October 2017 SUMMARY. The Arm s Length Principle
Russian Federation Transfer Pricing Country Profile Updated October 2017 SUMMARY REFERENCE The Arm s Length Principle 1 Does your domestic legislation or regulation make reference to the Arm s Length Principle?
More informationInternational tax changes may have a major impact on multinational tech companies
International tax changes may have a major impact on multinational tech companies Introduction Multinational technology companies face a swiftly changing international tax landscape. Monitoring the situation
More informationTransfer Pricing Country Summary Italy
Page 1 of 5 Transfer Pricing Country Summary Italy 01 July 2015 Page 2 of 5 Legislation Existence of Transfer Pricing Laws/Guidelines Transfer pricing legislation is laid down in Article 110, Para. 7,
More informationTransfer Pricing: The New Frontier Transfer Pricing Documentation in a Post-BEPS World: Evolution or Revolution? November 8, 2018
Transfer Pricing: The New Frontier Transfer Pricing Documentation in a Post-BEPS World: Evolution or Revolution? November 8, 2018 Today s Speakers Astrid Pieron Partner, Brussels apieron@mayerbrown.com
More informationTurkish Perspective on OECD Action Plan on Base Erosion and Profit Shifting
Turkey Ramazan Biçer and Mehmet Erginay* Turkish Perspective on OECD Action Plan on Base Erosion and Profit Shifting The OECD Action Plan on Base Erosion and Profit Shifting (BEPS) is a focal point of
More information