TPA Global. Top-10 Solutions. tpa-global.com

Similar documents
How To Reduce Transfer Pricing Compliance Costs?

Are you in control - TP Compliance Deadlines to look out for in 2018

Tax Technology Workshop 7 September 2017

New transfer pricing regulations in Poland in force since January 1st, 2017

Chinese Transfer Pricing Regulations and Their Implications

INTERNATIONAL TAX SOLUTIONS OVERVIEW

What is your CFO s plan for streamlining intra-group services? (1)

Resolving transfer pricing controversies, handling audits and queries, and best practices in TP documentation: A practical guide

TPA Global Treasury Playbook 2016

1. New decree on transfer-pricing documentation requirements

BEPS Country-by-Country Reporting Rules and New Documentation Requirements

CA T. P. OSTWAL. T. P. Ostwal & Associates LLP

International Transfer Pricing Framework

Services and Capabilities. Financial Services Transfer Pricing

Transfer pricing in the post-beps age The challenge to convert mere compliance into good governance

Austria publishes draft regulation for implementation of Transfer Pricing Documentation Law

Transfer Pricing based on HFM and TPH (Transfer Pricing for Hyperion) Matthew Prior & Neil Weller AMOSCA

BEPS ACTION 13 GUIDE HELPING YOUR ORGANIZATION BECOME BEPS COMPLIANT

OECD Publishes Guidance on Transfer Pricing Documentation and Country-by-Country Reporting

Practical Implications of BEPS

IFA MUNICH. Strategic Approaches to Global Transfer Pricing Risk: the use of tax treaties through APA and MAP. 18 January 2018

Strategic Planning, Forecasting & Budgeting

Annex I to Chapter V. Transfer pricing documentation Master file

International Transfer Pricing

Transfer Pricing Country Summary Turkey

Implementation of Masterfile and Localfile (BEPS Action 13) Georg Berka

Transfer Pricing Country Summary The Netherlands

Private sector members' paper outlining corporate tax transfer pricing risk assessment and management approaches.

IBFD Course Programme BEPS Country Implementation

EU JOINT TRANSFER PRICING FORUM

Principles of International Tax Planning

Prior to joining Microsoft, Angel worked for Arthur Andersen in their New York Office.

International Journal TM

Mr. Joe Andrus Head of Transfer Pricing Unit Centre for Tax Policy and Administration OECD 2, rue Andre Pascal Paris France.

LEARNING OBJECTIVES TRANSFER PRICING DOCUMENTATION. THE ROLE OF TPD Showing Compliance. Fundamentals of Transfer Pricing Documentation

HONG KONG. 1. Introduction. Contact Information Henry Fung Candice Ng

2017 Global BEPS Survey Report

IBFD Course Programme Transfer Pricing: Compliance and Audit Management in Southeast Asia

Analysis of Intellectual Property Tax Planning Strategies of Multinationals and the Impact of the BEPS Project

MALAYSIA TRANSFER PRICING LANDSCAPE

Chapter 2 - Business Framework: The Theory of the Firm and the Reasons for the Existence of Multinational Enterprises

Headline Verdana Bold International Tax matters ICPAU Tax Seminar, Hotel Africana November, 2017

Tax Evasion and Tax Compliance Theory and Policy

Transfer Pricing Country Summary Australia

Income Tax Workshop Base eroding payments Tax certainty and BEPS... 29

The Netherlands Digital Gateway to Europe 2016 Meijburg & Co, Tax Lawyers, is an association of limited liability companies under Dutch law,

Securing tomorrow today Setting up the tax function to embed controls around people, processes and systems

Creating cross-border tax efficiencies. Global Transfer Pricing Services. skpgroup.com

IBFD Course Programme Current Issues in International Tax Planning

EUROPEAN COMMISSION PRESENTS ANTI-TAX AVOIDANCE PACKAGE

IBFD Course Programme Transfer Pricing and Substance Masterclass

transfer pricing documentation

Base erosion & profit shifting (BEPS) 25 May 2016

Denmark. WTS Global Country TP Guide Last Update: December Legal Basis. 2. Master File (MF) Yes

Transfer Pricing: Future Trends. HLB International Conference Mark Gasbarra 3 December 2010 U.S. Virgin Islands

Value Chain Analysis. Roadmap to Being in Control

Transfer Pricing: The New Frontier Transfer Pricing Documentation in a Post-BEPS World: Evolution or Revolution? November 8, 2018

Chapter 2. Business Framework

What is Transfer Pricing and Why is it Important?

Transfer Pricing Country Summary Turkey

OECD/G20 Base Erosion and Profit Shifting Project

India releases Annual Report covering transfer pricing and international tax developments

Overview of OECD Action Plan on Base Erosion and Profit Shifting (BEPS)

Egypt implements new transfer pricing guidelines

Principles of Transfer Pricing

OECD DISCUSSION DRAFT ON TRANSFER PRICING COMPARABILITY AND DEVELOPING COUNTRIES

Chapter C.2. DOCUMENTATION

MANAGING TRANSFER PRICING ISSUES IN AN EVOLVING BEPS ENVIRONMENT

Transfer Pricing Administration in Italy 2.0: Are all the Questions Finally Answered?

IBFD Course Programme Principles of Transfer Pricing

By 13 September Dear Mr. Andrus,

The OECD s Discussion Draft on Transfer Pricing Documentation and Country-by-Country Reporting: A work in progress

TAX ALERT NEW CIRCULAR N 56/1 56BIS/1 ON THE TAX TREATMENT OF COMPANIES ENGAGED IN INTRA-GROUP FINANCING TRANSACTIONS JANUARY

Transfer Pricing for Africa - roundtable discussion. Transfer Pricing Special Event September 22, 2016

IBFD Course Programme Principles of Transfer Pricing

Navigating BEPS: Keeping track of the tax changes for internationally mobile employees

Recent Transfer Pricing Developments

Global Tax Alert. OECD releases report under BEPS Action 13 on Transfer Pricing Documentation and Country-by-Country Reporting.

Several members of the Subcommittee have contributed to this draft and appropriate attribution will be made in a later version.

Transfer Pricing in the Age of Transparency, Innovation, and Transformation

Future of TP. Documentation & Certification. 7th October Presented by- CA Dilip Gupta

Belgium. WTS Global Country TP Guide Last Update: December Legal Basis. 2. Master File (MF) Yes

The BEPS project is the beginning, but is the end in sight?

New post-beps three-tiered documentation requirements Impact for Kazakhstan s multinational enterprises

ROMANIA. minimum of 25% of the number/value of shares or voting rights in the two entities.

The OECD s 3 Major Tax Initiatives

Transfer Pricing Perspectives: The new normal: full TransParency. The post BEPS world in the automotive industry

Budget Seminar Overcoming the storm Chai Sui Fun and Falgun Thakkar PwC Singapore

Australia. Transfer Pricing Country Profile. Updated February The Arm s Length Principle

New Dutch transfer pricing decree implements OECD guidelines

IBFD Course Programme Current Issues in International Tax Planning

Tax footprint report 2017

Organisation for Economic Co-operation and Development (OECD) Attn. Mr. Jeffrey Owens OECD 2, rue André Pascal F Paris Cedex 16 France

IBFD Course Programme International Tax Planning after BEPS and the MLI

UN Releases Practical Manual on Transfer Pricing for Developing Countries

Global Transfer Pricing Review

Global Transfer Pricing Review

Chapter -1. An Introduction to Transfer Pricing

Managing operational tax risk through technology

Transfer Pricing Country Summary Israel

Transcription:

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 tax/tp workflows through design and implementation of a tax/tp framework. 3

Example: Being in control - Nine building blocks of a successful TP function (1/2) Systems used, storing of documents, update of documents Semiannual quick scan, defining TP methods used for price setting/price checking, processing / documentation of information, quality control Communication with tax inspector, sign off of responses to tax inspector, lead negotiation with tax authorities, communication to other stakeholders Documentation Consultancy Country risk matrix, Tax provision work, BEPS readiness check Data sourcing, date processing, quality control/final delivery Audit support Capacity planning Risk management Sign-off Sourcing of information, documentation of information, assessing validity of agreements, quality control Systems Global benchmarking platform Legal agreements Defining level of workflows that will be outsourced, defining hiring/firing strategy; implementing hiring/firing strategy Documentation, tax/ TP policy papers, audit, risk management projects, legal agreements Creation and maintenance of internal databases, update of existing benchmarks, identification of other benchmarking data sources, documentation of search strategies, ddefining use of external databases 4

Example: Being in control RACI matrix (2/2) Head of Tax Head of TP Central tax/ finace team Local tax/ finance team Legal team Business team... 1. Development/maintenance of TP documentation 2. Consultancy Advisory and implementation 3. Audit support 4. Risk Management 5. Systems (central data management & retrieval) 6. Capacity planning Insource/ outsource 7. Global benchmarking platform (outsourced to third parties) 8. Sign-off TP documents 9. Legal agreements- set up and implementation R (Responsible): Person who is assigned to perform part or all of the work, A (Accountable): Person who has the authority to sign off on the work before it is effective (ONLY ONE PERSON!), C (Consulted): Person who provides information or expertise necessary to complete the project, I (Informed): person who needs to be notified of results but need not necessary be consulted. 5

BEPS Readiness Test 6

2 Standardisation + Centralisation + Automation 3 must haves for Transfer Pricing TPA offers solutions for standardisation, centralisation and automation of key TP documents. 7

Introduction TPA Global approach to moving Clients TP compliance cycles towards higher efficiency BEPS compliant organisation + automated software solutions = increased process and compliance efficiency by >50% 8

Types of software applications Functionality MNEs need Description TP system design and planning Strategic & Operational TP Draws inter-company relationships (design) Links TP specialists recommendations to financials (test) TP capacity planning Strategic & Operational TP Assists in planning your insourcing/ outsourcing cycles Benchmarking Operational TP Automates comparable company searches Consultancy TP Knowledge Acts as a Google for transfer pricing TP report writing TP Compliance Generates standard TP documents, graphics, tables, etc. Generates CbC reports Audit process TP Compliance Streamlines tax audit process Records and maintains a log of all TP activities and calculations Tax provisioning TP Compliance Assists in reporting current and deferred income taxes Runs global tax provision calculations Data collection, retrieval & conversion TP Infrastructure Collects data in the right format Allows for standardized reporting across jurisdictions Workflow management TP Infrastructure Embeds workflows into an IT platform Enables automation of tax/ TP processes Repository for documents TP Infrastructure Contains streamlined and structured TP related information Automates document management 9

Software functionalities Functionality Transfer Pricing for Hyperion (TPH) Tax Series TP Genie (TPG) [X] View FinApp Suite Edgar Stat/ RoyaltyStat 1. TP system design and planning 2. TP capacity planning - - - - - - - - 3. Benchmarking - - - - 4. Consultancy - - - - - 5. TP report writing - - - 6. Audit process - - 7. Tax provisioning - - - - 8. Data collection, retrieval & conversion 9. Workflow management - - - 10. Repository for documents - - Not available, - Ready to be used by clients All functionalities of EdgarStat and RoyaltyStat are available only in relation to benchmarking and/or interpretation of comparables searches. 10

3 Value Chain Analytics A bridge to align corporate governance and operating models with tax/tp TPA offers VCA solutions including training and coaching, providing 4 techniques of VCA and automation through VCA software. 11

VCA Service Offerings Strategy Techniques References Industry Business Models Slicing the pie 1. Determine the need to change strategy 2. Competitor Analysis 3. Implement a change in strategy 1. Pie charts 2. Porter s method 3. Process contribution Analysis 4. Canvas Approach 1. Why are references important 2. OECD References 3. Country Specific References 4. Academic References 1. How to determine MNE s position in an industry 2. MNE Leadership Matrix 3. Three generations of governance and control 1. Shelf-life of business models 2. Measuring wall-to-wall profitability 3. Operational aspects of conducting a business and implementing new strategy 1. Focus on quantitative aspects of VCA 2. How to slice the pie between investment and profit center 3. Project management on VCA 12

VCA: BEPS Generation of Functional Analysis Pre BEPS Functional Analysis Economic Reality Move from Pre to Post BEPS Legal Reality Financial Reality Post BEPS Value Chain Analysis Operating model Corporate Governance Finance/Tax/TP Model 13

4 Automated CbC Reporting TPA Global offers software solutions to automate CbC reporting, including workshops and full implementation. 14

Country-by-Country reporting automation: Project charter 15

Country-by-Country reporting 16

5 Representation before tax authorities and courts TPA Global offers solutions for communication with tax authorities and courts on controversy and litigation matters. 17

How should business be addressing increased level of disputes? Multi-lateral Multi lateral APA/Map EU Commission Investigation EU Arbitration Conventions Joint Tax Audits Safe harbors ISO certificate G20/OECD listings E.g.: Exchange of information Re-active Mediation Pro-active Arbitrage committee under investment treaty Tax Audits Pre-audit settlement APA Local courts Uni-lateral Source: TPA Global Dispute Avoidance and Resolution Metrix 18

Controversy Management 19

Other Manufacturing Sales Disputes in the Value Chain of an MNE A. A value chain analysis after BEPS B. Dispute avoidance / resolution toolbox Valuation based allocation Residual Residual Multilateral APAs EU Arbitrage Court MAP Services Royalty / interest / guarantees etc. Mostly through audit process As sub part of APA C. Main questions: - which disputes to handle? - which toolbox to use? - what timing of risk management? - what professional process to use? What will be your Global TP risk mitigation strategy? Manufacturing Sales Services HQ / SSC / BU Unilateral APAs Mililateral APAs / industry standards ISO Cetificate Safe Harbor 20

Top-10 Non-TP Specific Solutions Overview 21

6 Solutions for Boards TPA offers various solutions to boards such as getting board decisions implemented within a 100 day framework by using strategy apps, change management and VCA tools. 22

COMPLETE PROCESS IN 90-100 DAYS Application of VCA: Fast Track Implementation Of Trigger Points Identify the decision makers Identify the way a business works 2 implementation steps towards a new operating model Thought Blueprint on corporate governance Blueprint on operating model Implementation 1 & Implementation 2 Finish 30 days 30 days 30 days Qualitative VCA Quantitative Change Management 23

Snapchats for Boards 24

7 Automated Global Tax Compliance TPA Global offers end-to-end automated Global Tax Compliance solutions starting from collecting data to the formal filing of corporate tax returns, Country-by-Country (CbC) Reporting, wages tax, property tax and VAT returns. 25

Automated Global Tax Compliance Solutions End-to-end automated GTC solutions Multinational enterprises with presence in 100+ countries Corporate Income Tax, Value-added Tax and Country-by-Country Reporting Global tax provisioning Multi-year tax planning, audit support and legal entity maintenance Task scheduling through tax calendar and document management in a single database 26

The Tax Engine The complete process of the automated GTC solutions, with the Tax Data Engine and Tax Compliance Engine as a backbone Complemented by centralized dashboards which allow all stakeholders to access and review the output of the respective engine 27

8 In-house Coaching and E-Learning Training/courses offered on corporate governance, strategy, leadership, and on tax and transfer pricing concepts 28

Courses offered by TPA Transfer Pricing - Fundamentals Value Creation Series - Value Creation for CFOs Authentic Governance and Control Framework Self Leadership Valuation Techniques - Valuation of Machinery and other Fixed Assets Transfer Pricing - BEPS for Beginners Value Creation Series - Building Smarter Companies Authentic Governance and Control Framework How to be in Control on Organizational Level Valuation Techniques - Valuation of Intangibles Transfer Pricing - Topics Value Creation Series - Defining Successful and Sustainable Value Chains Authentic Governance and Control Framework - Getting Acquainted for your Leaders Valuation Techniques - Valuation of Real Estate Transfer Pricing - Complexities Value Chain Analysis Valuation Techniques - Introduction to Valuation 29

9 Personalised Advisory Service TPA offers face-to-face video based advisory services with TPA professionals for addressing client questions. Prospects can book these sessions through TPA s website (24 sessions). 30

10 Valuation and Financial Modelling TPA offers a variety of valuation projects ranging from valuation of business models, customers lists and other intangibles. 31

Valuation tools and techniques As per the latest guidance issued by the OECD under its BEPS project, valuation techniques may be used as a part of one of the five OECD approved transfer pricing methods. In situations where reliable comparable uncontrolled transactions for a transfer of one or more intangibles cannot be identified, it may also be possible to use valuation techniques to estimate the arm s length price for intangibles transferred between associated enterprises. There are many variations of valuation techniques such as: - Discounted cash flow method This analysis looks at the cash flows generated by an asset and discounts these back to a present value using an appropriate discount rate or weighted average cost of capital. - Relief from royalty method This analysis is primarily used for valuation of intangible assets by identifying a comparable royalty for the asset being valued and the future cash flows from such royalty payments are capitalised to arrive at the net present value for the asset. - Historic and forecast earnings ratio This method is primarily used to value shares. A market multiple (obtained from third party data) is applied to the earnings of the company being valued to produce a valuation. - Option pricing Option pricing derived from standard calculation techniques like the Monte Carlo or Binomial approach effectively takes a discounted cash flow analysis and applies scenarios and criteria to calculate the value of an asset. 32

Valuation tools and techniques Transfer Pricing Associates offers valuation services in the following four areas: i. Tax Valuation of Shares Valuation of Intellectual Property Valuation of Business Restructuring ii. Financial reporting Purchase Price Allocation and Annual Impairment Test iii. Transactions Buy and sell side assistance Valuation support for joint ventures iv. Dispute resolution Damage quantification Financial litigation support 33

TPA Global provides international businesses with integrated and value-added solutions in improving financial performance, operational efficiency, strategic development and talent coaching through a cross-border and cross-discipline team of professionals which identifies the right solutions for customers and targets; efficient and streamlined advisory and implementation processes which cut through operational complexities across functions and borders; and superior customer service and support which proactively anticipate the evolving needs of the clients. H.J.E. Wenckebachweg 210. 1096 AS Amsterdam. The Netherlands. +31 (0)20 462 3530. The views expressed and the information provided in this material are of general nature and is not intended to address the circumstances of any particular individual or entity. The above content should neither be regarded as comprehensive nor sufficient for making decisions. No one should act on the information or views provided in this publication without appropriate professional advise. It should be noted that no assurance is given for any loss arising from any actions taken or to be taken or not taken by anyone based on this publication. 2018 Transfer Pricing Associates Holding B.V. All Rights Reserved. Taking control of the future