International Transfer Pricing Framework
|
|
- Maria Sims
- 6 years ago
- Views:
Transcription
1 Are you ready for transfer pricing? Seminar on November 28th, 2005 Swissotel, Istanbul International Framework Marc Diepstraten, Partner, PwC Amsterdam, PwC
2 Agenda Transfer pricing environment Transfer pricing methods Transfer pricing documentation Dispute resolution Recent developments Conclusion
3 Agenda Transfer pricing environment Transfer pricing methods Transfer pricing documentation Dispute resolution Recent developments Conclusion
4 Transfer pricing environment Global trading External Pressures Global trading New entrants Demand for consistency of service and solutions Increasing price transparency Low retail margins forcing down buying price Brand rationalization Dominance of retail brands Internal Pressures Inefficient processes Need to exploit - E-Business - Strategic sourcing - Tax rate differentials Rising personnel and property costs Demands from shareholders Technology not supporting customer requirements Page 4
5 Transfer pricing environment Global trading More than 70% of global trading transactions is intercompany! Global trading has impact on traditional way of doing business principal structures, tolling, SSC Local tax authorities may as a result of global trading loose (partially) their tax base of a company Important trading partners; US, Japan and EU have introduced and executed stringent transfer pricing legislation Focus of tax authorities to get fair share of total consolidated profits => Nr. 1 tool: transfer pricing adjustments Page 5
6 Transfer pricing environment Global trading Focus on transfer pricing results in: Installation and education of transfer pricing expert teams Introduction of local documentation requirements Increase of special transfer pricing tax audits Increase in transfer pricing disputes resulting in: - risk of economic double taxation - penalty for non-compliance - secondary adjustments - exchange of information between states Page 6
7 Transfer pricing environment Why is it important? If you are doing business internationally, you are already confronted with transfer pricing It is all about being in control and managing your risk Transfer pricing part of corporate governance policy Documentation Page 7
8 Transfer pricing environment Arm s length principle OECD Model Tax convention - Article 9: [When] conditions are made or imposed between... two [associated] enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. Page 8
9 Transfer pricing environment Legislative framework OECD Model Tax Convention (Article 9) OECD Guidelines Since 1995 including subsequent revisions Sets out methods for establishing arm s length transfer prices between related parties Endorsed by the member countries of the OECD Page 9
10 Transfer pricing environment EU Comprehensive transfer pricing regulations exist and are actively enforced in 18 of the 25 Member States of the EU: Austria Italy Cyprus Belgium Luxembourg Czech Republic Denmark Netherlands Estonia Finland Portugal Hungary France Spain Latvia Germany Sweden Lithuania Greece United Kingdom Malta Ireland Poland Slovakia Slovenia Page 10
11 Transfer pricing environment US- PATA Section 482 of the Code on arm s length dealings Surveys to examine transfer pricing methodologies under Section 482 The APA program Pacific Association of Tax Administrators (PATA) Documentation Package PATA issues guidance on Mutual Agreement Procedure and bilateral Advance Pricing Agreement processes Page 11
12 Agenda Transfer pricing environment Transfer pricing methods Transfer pricing documentation Dispute resolution Recent developments Conclusions
13 Transfer pricing methods Traditional transaction methods - Comparable Uncontrolled Price (CUP) - Cost Plus method (cost + ) - Resale Price method (resale minus) Transactional profit methods - Profit Split - Transactional Net Margin Method (TNMM) Other methods Page 13
14 Transfer pricing methods Terminology TURNOVER - COST OF GOODS SOLD Comparable Uncontrolled Price = GROSS PROFIT - OPERATING COSTS AND Resale Price Cost Plus Profit Split EXPENSES = OPERATING PROFIT / EBIT Transactional Net Margin Page 14
15 Transfer pricing methods Comparable uncontrolled price Uncontrolled transaction is comparable TP Subsidiary if; - No material differences effect the price (i.e. products, functions, contracts, economy, business strategy) Market price Third party - Reasonably accurate adjustments can be made Always the best method if comparable transactions are available Page 15
16 Transfer pricing methods Cost plus method Cost plus mark-up Transfer price Market price Costs Costs Supplier Distributor Page 16
17 Transfer pricing methods Cost plus method Transfer price is determined by cost of goods / services plus gross mark-up Mark up is determined by comparables search in light of functions and market conditions Cost base calculation problems Most useful for; - simple manufacturer - provision of services - long term supply agreements - semi finished goods Page 17
18 Transfer pricing methods Manufacturing companies - Considerations Cost plus and cost base - Type of costs to use: actual budget - by product by period - single billing entity (conversion to) - link with accounting manual - link with investment decisions Closure and relocation of manufacturing capacity Page 18
19 Transfer pricing methods Resale minus method Market price Transfer price Resale minus margin Costs Costs Supplier Distributor Page 19
20 Transfer pricing methods Resale minus method Transfer price is determined by resale price minus gross margin Gross margin is determined by comparables search in light of functions and market conditions Adjustments needed for differences in functions Most useful for; - distributor - marketing operations - finished goods or no important further processing by reseller Page 20
21 Transfer pricing methods Sales companies - Considerations Resale price minus and customer price - actual, price list and best customer - local stocks and adjustments - discounts and year-end bonus - documentation for tax audit - cost of invoicing Royalty and local marketing expenses ( Marketing intangibles ) Role of sales office Page 21
22 Transfer pricing methods Cost plus vs resale minus Product cost price 70 Market price 100 Cost plus 10% Resale margin 10% Manufacturer Distributor Customer Cost plus method: Resale minus method: Cost plus method: Resale minus method: Risks lie with distributor Risks lie with manufacturer Page 22
23 Transfer pricing methods Profit split Splits combined operating profit between related parties based upon functional risk profile Allocation of residual profit by using contribution indicators (i.e. contribution in intangible property) Based on expected rather than actual profits Most useful when no comparable prices or margins for specific transaction exist Page 23
24 Transfer pricing methods TNMM Evaluates operating profits before interest and tax by comparables search Usually results in a number of observations, and hence a range of potentially acceptable profit outcomes, typically expressed as a return on an appropriate base, such as turnover, costs or assets Commonly used because data is more readily available Number of observations Arm s length range Return % Page 24
25 Transfer pricing methods How to set the margin: Comparables Potential internal comparables Functional analysis Methods Adjustments Evaluation results reliability Potential external comparables Database studies Page 25
26 Transfer pricing methods How to set the margin: Comparables Look for; Internal comparables; i.e. transactions within the group with third parties External comparables through database search (benchmarking): TNMM approach Databases: Bureau van Dijk s AMADEUS and others Page 26
27 Transfer pricing methods OECD approach to comparability Transactional approach Transaction must be sufficiently comparable - no differences, or adjustable differences Factors in determining comparability - is it really the same product, service or intangible - contractual terms - market - differences in business strategy Assess comparability based on a functional analysis Page 27
28 Transfer pricing methods Other transfer pricing issues Intercompany services - HQ expenses / shared services Intangibles - trade name / trademarks Cost contribution / cost sharing - R&D programmes Reorganization business structures - Introduction of tollers / agents Permanent losses Page 28
29 Transfer pricing methods Other transfer pricing issues Intercompany services The low hanging fruit in transfer pricing! HQ services costs can be divided in three categories: - Direct costs - directly allocated to specific group beneficiary - Indirect costs - costs made for the group - allocated to all beneficiaries on bases of allocation yard stick - Stewardship / shareholders costs - not allocated, but are kept at central level Page 29
30 Transfer pricing methods Other transfer pricing issues Intercompany services Supporting contemporaneous documentation needed consisting of: - Service Level Agreement - Beneficiary test - Cost allocation schedule - Functional analysis at HQ level - Documentation on mark up used - Specified invoice! Page 30
31 Agenda Transfer pricing environment Transfer pricing methods Transfer pricing documentation Dispute resolution Recent developments Conclusions
32 Transfer pricing documentation Documentation challenge Global documentation requirements Can you afford not to be in compliance? What documentation strategies should you be employing? Page 32
33 Transfer pricing documentation Complexity check Sophisticated Medium Less sophisticated Sophisticated Medium Less sophisticated AUSTRALIA AUSTRIA CHINA BELGIUM HONG KONG CZECH REPUBLIC INDIA DENMARK INDONESIA FINLAND JAPAN FRANCE KOREA GERMANY MALAYSIA GREECE NEW ZEALAND HUNGARY PHILIPPINES IRELAND SINGAPORE ITALY TAIWAN LATVIA THAILAND LITHUANIA ARGENTINA NETHERLANDS CANADA NORWAY CHILE POLAND COLOMBIA PORTUGAL MEXICO ROMANIA PERU RUSSIA UNITED STATES SOUTH AFRICA VENEZUELA SLOVAK REPUBLIC SLOVENIA SPAIN SWEDEN SWITZERLAND UKRAINE UNITED KINGDOM Page 33
34 Transfer pricing documentation Purpose Define and agree on purpose of documentation, e.g.: Tax compliance Penalty protection Local documentation requirements Risk management Support Advance Pricing Agreements Management accounting Page 34
35 Transfer pricing documentation Framework Transfer pricing policy Transfer pricing report Transfer pricing board/audit manual Legal agreements Financial analysis Transfer prices Page 35
36 Transfer pricing documentation TP Report - High Level Table of Contents 1. Introduction 2. Company profile 3. Functional analysis (location of key value drivers) 4. Selection of transfer pricing methodology 5. Economic analysis (benchmarking) 6. Financial analysis (testing) 7. Conclusion Appendix I: Appendix II: Transfer pricing policy Relevant agreements Page 36
37 Transfer pricing documentation Process approach Analyse Design Implement Document Monitor Page 37
38 Transfer pricing documentation Process approach step 1: analyse Functional analysis Value chain analysis Identification of current intercompany transactions Key tax considerations Strategic objectives What are key value drivers? Risks Functions IP Page 38
39 Transfer pricing documentation Process approach step 1: analyse Functional analysis covers: - Key value drivers and their location - Key business risks and their location - Decision makers and their location - Assets employed - Intangibles used or created - Terms of trade - Background on the industry and market - Business strategy Page 39
40 Transfer pricing documentation Process approach step 2: design What are the opportunities associated with the implementation of a (new) transfer pricing framework, e.g.: Control Compliance with regulations Reduction effective tax rate Reduction cash tax What are the risks associated with the implementation of a (new) transfer pricing framework, e.g.: Cross border shifts of profits Opening up the past IT constraints Not alignment with business structure Limited resources Page 40
41 Transfer pricing documentation Process approach step 3: implement Stakeholders who and their roles Resources available internal / external Work plan / Milestones Communication internal/external IT ERP systems and administration Legal agreements / IP and labour law issues Page 41
42 Transfer pricing documentation Process approach step 4: document Step 1: Step 2: Step 3: Step 4: Prepare one central core documentation file (per region) Decide on priority/risk countries. Factors include: - Financial size of transactions - Importance of local markets - Fluctuations in results - Structural loss-making countries - Transfer pricing documentation rules - Penalty regimes - Need of business for guidance Local country review of core file in selected countries Roll-out core file locally Page 42
43 Transfer pricing documentation Process approach step 5: monitor Check invoice is in line with policy Check whether all agreements, documentation are in place Review financial performance of transfer pricing budget (actual vs. budgets) Overall review (check whether performance transfer pricing system conform expectations) Seek proactive clearance if Advance Pricing Agreement is possible Rely on documentation to manage tax audit Page 43
44 Transfer pricing documentation PwC Approach: Global Core Documentation Core Document Local Document Global Core Documentation Package Coordinated international service team approach Risk assessment & non-duplicative data collection Consistent functional analysis & methodology Efficiencies through specialized tools, templates & procedures Quality & cost control tool Centralize preparation of core documentation package Customization to meet country-specific requirements Different levels of documentation for different needs Page 44
45 Agenda Transfer pricing environment Transfer pricing methods Transfer pricing documentation Dispute resolution Recent developments Conclusions
46 Dispute resolution What are the tools? After double taxation may occur: - Mutual Agreement Procedures (MAP) under Treaty (i.e. Turkish treaty network) - EU Arbitration Convention - Advance Pricing Agreements (APA) as roll back facility Before double taxation may occur: - Advance Pricing Agreements (APA) as a mean of dispute resolution: unilateral, bilateral, multilateral Page 46
47 Dispute resolution Mutual agreement procedure Article 25 in the OECD Model Treaty The competent authority shall endeavor... to resolve with the competent authority of the other state No obligation to reach agreement No deadlines: normally takes a long time (average processing time within EU 20 months) Overall success rate is 85% for MAP within EU Page 47
48 Dispute resolution Mutual agreement procedure - Turkey Tax treaty network with 61 countries Competent authority: Double Taxation Agreements Division under Directorate General of Revenues No obligation for relief of double taxation 3 years filing period under most of the treaties No domestic guidelines for mutual agreement procedure No procedural requirements for mutual agreement procedure Detailed knowledge of the issue is a success factor Page 48
49 Dispute resolution EU Arbitration Convention To eliminate double taxation between member states Provides for mandatory arbitration in cases where Member States cannot reach mutual agreement If no mutual agreement between tax authorities is reached within 2 years advisory commission must arbitrate in the case Was in force for initial period 1995 until 2000 Re-entered into force on 2004 with retroactive effect from 2000 Specific deadlines provided (3 years in total) Code of Conduct published in 2004 for effective implementation Page 49
50 Dispute resolution Advance pricing agreements Paragraph OECD Guidelines (1995) Annex to the OECD Guidelines (1999) Provisions in domestic legislation (USA, Japan, Australia, UK, Spain, Belgium, The Netherlands, Canada, Mexico, China..) Possible as part of mutual agreement procedure under the treaty (bilateral) Informal agreement with tax authority (unilateral) Page 50
51 Dispute resolution Advance pricing agreements Advance Pricing Fixed period of time Future events / transactions Transfer pricing techniques and rules Products, services, IP, loans and allocation of central expenses Parents, subsidiaries and permanent establishments Entrepreneur <-> least complex entity Key value drivers Agreement Tax payer and government Unilateral / bilateral / multilateral Page 51
52 Dispute resolution First multilateral APA signed in Europe for Airbus Strong signal by EU tax authorities (France, Germany, UK, Spain) Cooperative process Finding consensus Result in reasonable timing Page 52
53 Agenda Transfer pricing environment Transfer pricing methods Transfer pricing documentation Dispute resolution Recent developments Conclusions
54 Recent developments EU Joint Forum - Master file concept OECD developments - KERT discussion EU Debate Page 54
55 Recent developments Master file concept New: Approval of code of conduct on standardised documentation in the EU November 2005 EU Documentation ( EU TPD ) is proposed Master file as a blueprint for companies and their transfer pricing systems Proposes that companies can use same documentation in all member states Will ease heavy burden on companies of different documentation requirements EU TPD is still optional Page 55
56 Recent developments Master file concept Master file a) general description of the business b) the group s organisational, legal and operational structure c) general identification of the associated enterprises engaged in controlled transactions d) general description of the controlled transactions e) general description of functions and risks f) ownership of intangibles g) inter-company transfer pricing policy h) list of Cost Contribution Agreements, APAs and Rulings i) undertaking by the taxpayer to provide additional information upon request Minimum requirement for master file Country specific documentation a) detailed description of the business and business strategy b) information on country specific controlled transactions c) comparability analysis d) explanation about the selection and application of the transfer pricing method [s] e) relevant information on internal and/or external comparables if available f) a description of the implementation and application of the group's transfer pricing policy Page 56
57 Recent developments OECD draft paper on attribution of profits to permanent establishments Income allocation between head office and PE PE treated as a notional separate entity Two step working hypothesis to determine profits attributable to PE 1- Determine the functions performed, assets used and risks assumed by the PE 2- Attribute to the PE an arm s length return for the functions performed, assets used, and risks assumed by the PE as would a comparable enterprise Page 57
58 Recent developments OECD KERT discussion Key Entrepreneurial Risk Taking Functions (KERTs) discussion: Risks follow functions Profits follow people Active decision making with regards to most important profit generators Thus: profits can be allocated to locations where relevant risks are managed. Page 58
59 Recent developments OECD KERT discussion Common principal company structure: OECD view: Head office Head office cost plus fee cost plus fee Divisional head office Principal Residual profit cost plus fee cost plus fee Operations Operations Residual profit Page 59
60 Recent developments The European Debate All EU countries apply OECD Guidelines but European Commission found significant difference per country All countries have a strong preference for CUP, resale minus and cost plus methods Although there are no public data at transactional level to support these methods Profit based methods are under discussion Page 60
61 Agenda Transfer pricing environment Transfer pricing methods Transfer pricing documentation Dispute resolution Recent developments Conclusions
62 Conclusions What are the next steps? Be aware of rapid global developments Be ready to comply with proposed Turkish TP legislation Time to act! Develop transfer pricing strategy Develop documentation Page 62
63 pwc
Reporting practices for domestic and total debt securities
Last updated: 27 November 2017 Reporting practices for domestic and total debt securities While the BIS debt securities statistics are in principle harmonised with the recommendations in the Handbook on
More informationGuidance on Transfer Pricing Documentation and Country-by-Country Reporting
OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting ACTION 13: 2014 Deliverable ANNEX II TO CHAPTER V. TRANSFER PRICING DOCUMENTATION
More informationSTOXX EMERGING MARKETS INDICES. UNDERSTANDA RULES-BA EMERGING MARK TRANSPARENT SIMPLE
STOXX Limited STOXX EMERGING MARKETS INDICES. EMERGING MARK RULES-BA TRANSPARENT UNDERSTANDA SIMPLE MARKET CLASSIF INTRODUCTION. Many investors are seeking to embrace emerging market investments, because
More informationTransfer Pricing in Botswana and Southern Africa. Christian Wiesener KPMG Global Transfer Pricing Services 26 June 2014
Transfer Pricing in Botswana and Southern Africa Christian Wiesener KPMG Global Transfer Pricing Services 26 June 2014 Agenda Introduction to Transfer Pricing Transfer Pricing Example Africa Transfer Pricing
More informationAPA & MAP COUNTRY GUIDE 2017 CANADA
APA & MAP COUNTRY GUIDE 2017 CANADA Managing uncertainty in the new tax environment CANADA KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance criteria Key
More informationAPA & MAP COUNTRY GUIDE 2017 UNITED STATES
APA & MAP COUNTRY GUIDE 2017 UNITED STATES Managing uncertainty in the new tax environment UNITED STATES KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance
More informationGlobal Tax Reset Transfer Pricing Documentation Summary. February 2018
Global Tax Reset Transfer Pricing Summary February 2018 Global Tax Reset Transfer Pricing Summary Overview The Global Tax Reset Transfer Pricing Summary ( Guide ) compiles essential country-by-country
More informationFinancial wealth of private households worldwide
Economic Research Financial wealth of private households worldwide Munich, October 217 Recovery in turbulent times Assets and liabilities of private households worldwide in EUR trillion and annualrate
More informationTAXATION OF TRUSTS IN ISRAEL. An Opportunity For Foreign Residents. Dr. Avi Nov
TAXATION OF TRUSTS IN ISRAEL An Opportunity For Foreign Residents Dr. Avi Nov Short Bio Dr. Avi Nov is an Israeli lawyer who represents taxpayers, individuals and entities. Areas of Practice: Tax Law,
More informationSummary of key findings
1 VAT/GST treatment of cross-border services: 2017 survey Supplies of e-services to consumers (B2C) (see footnote 1) Supplies of e-services to businesses (B2B) 1(a). Is a non-resident 1(b). If there is
More informationAllocation of income post-beps
Allocation of income post-beps EMA Tax Summit London, September 2016 Download the app Open a web browser on your mobile and navigate to http://mobile.globaltaxevent.com Use WiFi for better speed. Select
More informationCorrigendum. OECD Pensions Outlook 2012 DOI: ISBN (print) ISBN (PDF) OECD 2012
OECD Pensions Outlook 2012 DOI: http://dx.doi.org/9789264169401-en ISBN 978-92-64-16939-5 (print) ISBN 978-92-64-16940-1 (PDF) OECD 2012 Corrigendum Page 21: Figure 1.1. Average annual real net investment
More informationAPA & MAP COUNTRY GUIDE 2017 DENMARK
APA & MAP COUNTRY GUIDE 2017 DENMARK Managing uncertainty in the new tax environment DENMARK KEY FEATURES Competent authority Danish Tax Office ( SKAT ) APA provisions/ guidance Types of APAs available
More informationwts study Global WTS PE Study A high-level overview of most discussed PE issues in EU, OECD and BRICS countries
wts study Global WTS PE Study A high-level overview of most discussed PE issues in EU, OECD and BRICS countries Table of Contents Preface 3 Conclusions at a glance 4 Summary from the survey 5 Detailed
More information10 Countries. 1 Company.
10 Countries. 1 Company. Transfer Pricing Risk Management Iris Burgstaller 2 March 2011 Klaus Krammer TPA Horwath Group Locations 10 countries 25 offices around 960 employees page 2 Overview 1. Transfer
More informationGuide to Treatment of Withholding Tax Rates. January 2018
Guide to Treatment of Withholding Tax Rates Contents 1. Introduction 1 1.1. Aims of the Guide 1 1.2. Withholding Tax Definition 1 1.3. Double Taxation Treaties 1 1.4. Information Sources 1 1.5. Guide Upkeep
More informationEQUITY REPORTING & WITHHOLDING. Updated May 2016
EQUITY REPORTING & WITHHOLDING Updated May 2016 When you exercise stock options or have RSUs lapse, there may be tax implications in any country in which you worked for P&G during the period from the
More informationFinancial law reform: purpose and key questions
Conference on Cross-Jurisdictional Netting and Global Solutions Update on Netting in Asia May 12, 2011 London School of Economics and Political Science Peter M Werner Senior Director ISDA pwerner@isda.org
More informationUkraine. WTS Global Country TP Guide Last Update: December Legal Basis
Ukraine WTS Global Country TP Guide Last Update: December 2017 1. Legal Basis Is there a legal requirement to prepare TP documentation? Since when does a TP documentation requirement exist in your country?
More informationApproach to Employment Injury (EI) compensation benefits in the EU and OECD
Approach to (EI) compensation benefits in the EU and OECD The benefits of protection can be divided in three main groups. The cash benefits include disability pensions, survivor's pensions and other short-
More informationBEPS Actions implementation by country Actions 8-10 Transfer pricing
BEPS Actions implementation by country Actions 8-10 Transfer pricing On 5 October 2015, the G20/OECD published 13 final reports and an explanatory statement outlining consensus actions under the base erosion
More informationRevenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings
Revenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings Page 1 of 21 Table of Contents 1. Introduction...3 2. Overview of Council Directive (EU)
More informationFinland Country Profile
Finland Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Finland EU Member State Double Tax Treaties With: Argentina Armenia Australia
More information15 Popular Q&A regarding Transfer Pricing Documentation (TPD) In brief. WTS strong presence in about 100 countries
15 Popular Q&A regarding Transfer Pricing Documentation (TPD) Contacts China Martin Ng Managing Partner Martin.ng@worldtaxservice.cn + 86 21 5047 8665 ext.202 Xiaojie Tang Manager Xiaojie.tang@worldtaxservice.cn
More informationSlovakia Country Profile
Slovakia Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Slovakia EU Member State Double Tax Treaties Yes With: Australia Austria Belarus
More informationSwitzerland Country Profile
Switzerland Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Switzerland EU Member State No. Please note that, in addition to Switzerland
More informationDeadlines to preserve taxpayer rights to request competent authority assistance to relieve double taxation
Arm s Length Standard Global views within reach. Deadlines to preserve taxpayer rights to request competent authority assistance to relieve double taxation Transfer pricing continues to be the top enforcement
More informationOverview of Transfer Pricing Regulations. CA Akshay Kenkre
Overview of Transfer Pricing Regulations CA Akshay Kenkre 1 What is Transfer Pricing What is Transfer Price? A Price at which one person transfers physical goods, services, tangible or/ and intangibles
More informationEnterprise Europe Network SME growth outlook
Enterprise Europe Network SME growth outlook 2018-19 een.ec.europa.eu 2 Enterprise Europe Network SME growth outlook 2018-19 Foreword The European Commission wants to ensure that small and medium-sized
More informationTransfer pricing of intangibles
32E30000 - Tax Planning of International Enterprises Transfer pricing of intangibles Aalto BIZ / May 2, 2016 Petteri Rapo Alder & Sound Mannerheimintie 16 A FI-00100 Helsinki firstname.lastname@aldersound.fi
More informationAustria Country Profile
Austria Country Profile EU Tax Centre March 2014 Key tax factors for efficient cross-border business and investment involving Austria EU Member State Yes Double Tax Treaties With: Albania Algeria Armenia
More informationBurden of Taxation: International Comparisons
Burden of Taxation: International Comparisons Standard Note: SN/EP/3235 Last updated: 15 October 2008 Author: Bryn Morgan Economic Policy & Statistics Section This note presents data comparing the national
More informationPublic Pension Spending Trends and Outlook in Emerging Europe. Benedict Clements Fiscal Affairs Department International Monetary Fund March 2013
Public Pension Spending Trends and Outlook in Emerging Europe Benedict Clements Fiscal Affairs Department International Monetary Fund March 13 Plan of Presentation I. Trends and drivers of public pension
More informationDouble Tax Treaties. Necessity of Declaration on Tax Beneficial Ownership In case of capital gains tax. DTA Country Withholding Tax Rates (%)
Double Tax Treaties DTA Country Withholding Tax Rates (%) Albania 0 0 5/10 1 No No No Armenia 5/10 9 0 5/10 1 Yes 2 No Yes Australia 10 0 15 No No No Austria 0 0 10 No No No Azerbaijan 8 0 8 Yes No Yes
More informationSwitzerland Country Profile
Switzerland Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Switzerland EU Member State No. Please note that, in addition to Switzerland
More informationGlobal Business Barometer April 2008
Global Business Barometer April 2008 The Global Business Barometer is a quarterly business-confidence index, conducted for The Economist by the Economist Intelligence Unit What are your expectations of
More informationOther Tax Rates. Non-Resident Withholding Tax Rates for Treaty Countries 1
Other Tax Rates Non-Resident Withholding Tax Rates for Treaty Countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15
More informationOpen Day 2017 Clearstream execution-to-custody integration Valentin Nehls / Jan Willems. 5 October 2017
Open Day 2017 Clearstream execution-to-custody integration Valentin Nehls / Jan Willems 5 October 2017 Deutsche Börse Group 1 Settlement services: single point of access to cost-effective, low risk and
More informationNon-resident withholding tax rates for treaty countries 1
Non-resident withholding tax rates for treaty countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15 15/25 Armenia
More informationIV Tax Administration in the Era of Globalization
IV The NTA promotes tax administration, including cooperation with foreign tax authorities to meet the era of globalization. As multinational enterprises conduct various cross-border economic activities
More informationwww.bakertillyinternational.com Arm's Length Principle Transfer Pricing Methods From January 1997, as part of the tax reform, new transfer pricing rules based on the arm's length principle have been applicable,
More informationAPA & MAP COUNTRY GUIDE 2018 UKRAINE. New paths ahead for international tax controversy
APA & MAP COUNTRY GUIDE 2018 UKRAINE New paths ahead for international tax controversy UKRAINE APA PROGRAM KEY FEATURES Competent authority Relevant provisions Types of APAs available Acceptance criteria
More informationVinodh & Muthu. Tax Alert. Insight. Chartered Accountants. Country by Country Reporting & Master File
Vinodh & Muthu Chartered Accountants Tax Alert Country by Country Reporting & Master File Insight The Organisation for Economic Cooperation and Development ( OECD ) report on Action 13 of Base Erosion
More informationThe Global Tax Reset 2017 Audit Committee Symposium
The Global Tax Reset Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 1 The Global Tax Reset General context Multinational companies
More informationSweden Country Profile
Sweden Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Sweden EU Member State Double Tax Treaties With: Albania Armenia Argentina Azerbaijan
More informationSetting up in Denmark
Setting up in Denmark 6. Taxation The Danish tax system for individuals rests on the global taxation principle. The principle holds that the income of individuals and companies with full tax liability
More informationKey Issues in the Design of Capital Gains Tax Regimes: Taxing Non- Residents. 18 July 2014
Key Issues in the Design of Capital Gains Tax Regimes: Taxing Non- Residents 18 July 2014 How do we tax non-residents on capital income? Domestic design issues Tax treaty issues Interrelationship between
More informationDefinition of international double taxation
Definition of international double taxation Juridical double taxation: imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical
More informationAPA & MAP COUNTRY GUIDE 2017 MOROCCO
APA & MAP COUNTRY GUIDE 2017 MOROCCO Managing uncertainty in the new tax environment MOROCCO KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance criteria Key
More informationSan Francisco Retiree Health Care Trust Fund Education Materials on Public Equity
M E K E T A I N V E S T M E N T G R O U P 5796 ARMADA DRIVE SUITE 110 CARLSBAD CA 92008 760 795 3450 fax 760 795 3445 www.meketagroup.com The Global Equity Opportunity Set MSCI All Country World 1 Index
More informationBelgium Country Profile
Belgium Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Belgium EU Member State Double Tax Treaties Yes With: Albania Algeria Argentina
More informationStatistical annex. Sources and definitions
Statistical annex Sources and definitions Most of the statistics shown in these tables can be found as well in several other (paper or electronic) publications or references, as follows: the annual edition
More informationSerbia Country Profile
Serbia Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Serbia EU Member State Double Tax Treaties With: Albania Austria Azerbaijan Belarus
More informationSummary 715 SUMMARY. Minimum Legal Fee Schedule. Loser Pays Statute. Prohibition Against Legal Advertising / Soliciting of Pro bono
Summary Country Fee Aid Angola No No No Argentina No, with No No No Armenia, with No No No No, however the foreign Attorneys need to be registered at the Chamber of Advocates to be able to practice attorney
More informationGuidance on Transfer Pricing Documentation and Country-by-Country Reporting
OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting ACTION 13: 2014 Deliverable ANNEX III TO CHAPTER V. A MODEL TEMPLATE FOR THE
More informationRecommendation of the Council on Tax Avoidance and Evasion
Recommendation of the Council on Tax Avoidance and Evasion OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD Legal Instrument
More informationAPA & MAP COUNTRY GUIDE 2017 CROATIA
APA & MAP COUNTRY GUIDE 2017 CROATIA Managing uncertainty in the new tax environment CROATIA KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance criteria Key
More informationKPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX
KPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX B KPMG s Individual Income Tax and Social Security Rate Survey 2009 KPMG s Individual Income Tax and Social Security Rate Survey 2009
More informationThird Revised Decision of the Council concerning National Treatment
Third Revised Decision of the Council concerning National Treatment OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationStudy Presentation. Vice President, OPORA RUSSIA. N.I. Zolotykh. July 9, 2010.
Study Presentation Vice President, OPORA RUSSIA N.I. Zolotykh July 9, 2010. 1 Study Partners RUSNANO T h e p r o j e c t w a s p e r f o r m e d b y : B a u m a n I n n o v a t I o n / S t r a t e g y
More informationNational Tax Agency, Japan
(Mutual Agreement Procedures) Report 214 When international double taxation arises from transfer pricing adjustments or other tax adjustments, the National Tax Agency ( NTA ) enters into Mutual Agreement
More informationMadeira: Global Solutions for Wise Investments
Madeira: Global Solutions for Wise Investments Double Taxation Treaties Document downloaded from www.ibc-madeira.com DOUBLE TAXATION TREATIES RATIFIED BY PORTUGAL Europe RATIFICATION/ENTRY INTO FORCE AUSTRIA
More informationTPA Global Treasury Playbook 2016
TPA Global Treasury Playbook 2016 Transfer Pricing Solutions for Financial Transactions 4 th Edition Are You In Control? What are the 2017 trends and topics for intercompany financial transactions? 1.
More informationIreland signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
17 July 2017 Global Tax Alert Ireland signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationStatistics on APAs in the EU at the End of 2014
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTO UNION Direct taxation, Tax Coordination, Economic Analysis and Evaluation Direct Tax Policy and Cooperation Brussels, October 2015 Taxud/D2 DOC:
More informationCapital Markets Day 2011
Capital Markets Day 2011 DSV Air & Sea Division Jorgen Moller, President DSV Air & Sea Holding A/S Capital Markets Day 6 September 2011 Agenda 1. DSV Air & Sea - general facts 2. Update on H1 2011 3. Growth
More informationFTSE Global Equity Index Series
Methodology overview FTSE Global Equity Index Series Built for the demands of global investors Indexes for a global market The FTSE Global Equity Index Series (FTSE GEIS) includes objective, rules-based
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Czech Rep. EU Member State Yes Double Tax With: Treaties Albania Armenia
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationIreland Country Profile
Ireland Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Ireland EU Member State Yes Double Tax Treaties With: Albania Armenia Australia
More informationDOMESTIC CUSTODY & TRADING SERVICES
Pricing Structure DOMESTIC CUSTODY & TRADING SERVICES A flat custody fee of 20bps per account type per year is applicable to all holdings and cash, the custody fee is collected each month but will be capped
More informationRev. Proc Implementation of Nonresident Alien Deposit Interest Regulations
Rev. Proc. 2012-24 Implementation of Nonresident Alien Deposit Interest Regulations SECTION 1. PURPOSE Sections 1.6049-4(b)(5) and 1.6049-8 of the Income Tax Regulations, as revised by TD 9584, require
More informationTransfer Pricing Essentials. Steven C. Wrappe KPMG LLP Washington, D.C.
Transfer Pricing Essentials Steven C. Wrappe KPMG LLP Washington, D.C. Notice The following information is not intended to be written advice concerning one or more Federal tax matters subject to the requirements
More informationTHIRD MEETING OF THE OECD FORUM ON TAX ADMINISTRATION
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT THIRD MEETING OF THE OECD FORUM ON TAX ADMINISTRATION 14-15 September 2006 Final Seoul Declaration CENTRE FOR TAX POLICY AND ADMINISTRATION 1 Sharing
More informationCorporate Governance and
Corporate Governance and Third Edition Jill Solomon )WILEY A John Wiley and Sons, Ltd, Publication Preface Acknowledgements Introducton xv xvii xix Part I Corporate governance: frameworks and mechanisms
More informationFATCA Update May 2014
www.pwc.com The Basics Foreign Account Tax Compliance Act Purpose of Prevent and detect offshore tax evasion by US citizens Increased information reporting Enforced by withholding tax Effective begins
More information(of 19 March 2013) Valid from 1 January A. Taxpayers
Leaflet. 29/460 of the Cantonal Tax Office on withholding taxes applicable to pension benefits under private law for persons without domicile or residence in Switzerland (of 19 March 2013) Valid from 1
More informationTotal Imports by Volume (Gallons per Country)
3/7/2018 Imports by Volume (Gallons per Country) YTD YTD Country 01/2017 01/2018 % Change 2017 2018 % Change MEXICO 54,235,419 58,937,856 8.7 % 54,235,419 58,937,856 8.7 % NETHERLANDS 12,265,935 10,356,183
More informationTotal Imports by Volume (Gallons per Country)
5/4/2016 Imports by Volume (Gallons per Country) YTD YTD Country 03/2015 03/2016 % Change 2015 2016 % Change MEXICO 53,821,885 60,813,992 13.0 % 143,313,133 167,568,280 16.9 % NETHERLANDS 11,031,990 12,362,256
More informationMarine. Global Programmes. cunninghamlindsey.com. A Cunningham Lindsey service
Marine Global Programmes A Cunningham Lindsey service Marine global presence Marine Global Programmes Cunningham Lindsey approach Managing your needs With 160 marine surveyors and claims managers in 36
More informationTurkey Country Profile
Turkey Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Turkey EU Member State Double Tax Treaties With: Albania Algeria Australia Austria
More informationMPF & Retirement Protection System in Hong Kong A personal view
MPF & Retirement Protection System in Hong Kong A personal view Darren McShane Chief Regulation & Policy Officer and Executive Director Mandatory Provident Fund Schemes Authority 21 March 2017 Agenda I.
More informationInternational Tax Conference
International Tax Conference Hong Kong s Experience with its International Tax Treaty Network Richard Wong Commissioner of Inland Revenue 19 June 2014 1 Introduction Purpose of signing a tax treaty Fairness
More informationSlovenia Country Profile
Slovenia Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Slovenia EU Member State Double Tax Treaties With: Albania Armenia Austria
More informationTurkey Country Profile
Turkey Country Profile EU Tax Centre June 2018 EU Tax Centre June 2018 Turkey Key tax factors for efficient cross-border business and investment involving Turkey EU Member State Double Tax Treaties No
More informationDouble tax considerations on certain personal retirement scheme benefits
www.pwc.com/mt The elimination of double taxation on benefits paid out of certain Maltese personal retirement schemes February 2016 Double tax considerations on certain personal retirement scheme benefits
More informationInternational Statistical Release
International Statistical Release This release and additional tables of international statistics are available on efama s website (www.efama.org). Worldwide Investment Fund Assets and Flows Trends in the
More informationNEXIA SURVEY QUESTIONNAIRE
NEXIA SURVEY QUESTIONNAIRE - Application of the Authorized OECD-approach (AOA) (July 2014) A. Background On 22 July 2010 the OECD released the Update 2010 to the OECD Model Tax Convention and its Commentary
More informationThe Rule of Law as a Factor for Competitiveness
The Rule of Law as a Factor for Competitiveness Lessons from the Global Competitiveness Index 2008-2009 Irene Mia Director, Senior Economist Global Competitiveness Network, World Economic Forum OECD Workshop
More informationGlobal Consumer Confidence
Global Consumer Confidence The Conference Board Global Consumer Confidence Survey is conducted in collaboration with Nielsen 4TH QUARTER 2017 RESULTS CONTENTS Global Highlights Asia-Pacific Africa and
More informationAlter Domus IRELAND WE RE WHERE YOU NEED US.
WE RE WHERE YOU NEED US. Alter Domus is a fully integrated Fund and Corporate services provider, dedicated to international private equity & infrastructure houses, real estate firms, multinationals, private
More informationStatistical Annex ANNEX
ISBN 92-64-02384-4 OECD Employment Outlook Boosting Jobs and Incomes OECD 2006 ANNEX Statistical Annex Sources and definitions Most of the statistics shown in these tables can be found as well in three
More informationLithuania Country Profile
Lithuania Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Lithuania EU Member State Yes Double Tax Treaties With: Armenia Austria Azerbaijan
More informationWHY UHY? The network for doing business
The network for doing business the network for doing business UHY has over 6,800 professionals to choose from trusted advisors and consultants operating in more than 250 business centres, based in 81 countries
More informationInternational Statistical Release
International Statistical Release This release and additional tables of international statistics are available on efama s website (www.efama.org) Worldwide Investment Fund Assets and Flows Trends in the
More informationTAX INFORMATION PORTUGUESE INTERNATIONAL DOUBLE TAXATION TREATIES. PLMJ Sharing Expertise. Innovating Solutions. April 2011
TAX INFORMATION PLMJ April 2011 PORTUGUESE INTERNATIONAL DOUBLE TAXATION TREATIES International double taxation is an obstacle to trade relations and to the free movement of goods, services, people and
More informationA. Definitions and sources of data
Poland A. Definitions and sources of data Data on foreign direct investment (FDI) in Poland are reported by the National Bank of Poland (NBP), the Polish Agency for Foreign Investment (PAIZ) and the Central
More informationWithholding Tax Handbook BELGIUM. Version 1.2 Last Updated: June 20, New York Hong Kong London Madrid Milan Sydney
Withholding Tax Handbook BELGIUM Version 1.2 Last Updated: June 20, 2014 Globe Tax Services Incorporated 90 Broad Street, New York, NY, USA 10004 Tel +1 212 747 9100 Fax +1 212 747 0029 Info@GlobeTax.com
More informationDeveloping Housing Finance Systems
Developing Housing Finance Systems Veronica Cacdac Warnock IIMB-IMF Conference on Housing Markets, Financial Stability and Growth December 11, 2014 Based on Warnock V and Warnock F (2012). Developing Housing
More information