Transfer pricing
A global view on a business-critical, fast-evolving issue.
The transfer pricing landscape in Central and Eastern Europe (CEE) is rapidly evolving. Companies need to anticipate and be reactive to change, and simultaneously manage their documentation requirements to avoid any delays. They must also ensure their group’s transfer pricing policies and obligations are met to mitigate any associated risk of non-compliance.
Agenda:
Moderator: Gertrud Bergmann, Transfer Pricing Partner at Forvis Mazars Germany
1. New international tax framework: what would be the impact on transfer pricing? - 21 October, 14:00 CET
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In October 2019, the OECD Secretariat presented the "Unified Approach" for the taxing rights’ reallocation of MNEs’ profits.
One year later, the OECD released pillar one and pillar two blueprints that develop a framework to address the taxation of the digitalized economy, and introduce a global minimum tax regime to fight against base erosion and profit shifting.
This "Unified Approach" focuses on large and consumer-facing companies. A new nexus is proposed to ensure taxation of corporate profits in markets where a certain sales threshold is reached without being physical present. Thus, MNEs need to prepare for the changes in international tax rules.
Our Forvis Mazars experts will provide you with a clear understanding of the key risks for MNEs’ operational and business models, and will analyze the impact on transfer pricing.
Agenda:
• Impact of the harmonization of corporate tax rates on transfer pricing, Cormac Kelleher, Partner at Forvis Mazars Ireland
• Impact of Pillar 1 on transfer pricing, Ben Semper, director at Forvis Mazars UK
• Impact of Pillar 2 on transfer pricing, Erin Alexander, director at Forvis Mazars USA
Moderated by: Frédéric Barat, Partner at Forvis Mazars France
2. How can multinational companies mitigate the impact of Covid-19 on their Transfer Pricing reviews? - 21 September 2021, 14:00 CET
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The Covid-19 pandemic will have serious implications on transfer pricing for many multinational enterprises (MNEs) in the upcoming years. In December 2020, the OECD released its Guidance that clarifies and illustrates the practical application of the arm’s length principle as articulated in their Transfer Pricing Guidelines.
Four priority issues were identified and covered in the Guidance:
Agenda:
Speakers:
Moderated by: Gertrud Bergmann, Partner at Forvis Mazars Germany
3. Business restructuring: transfer pricing aspects - 17 June 2021, 14:00 CET
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Due to Covid-19, multinational companies might have to adapt the way they do business and restructure their organisation, including their supply chain. Such reorganisation may involve the transfer of valuable intangible assets to other countries and, or lead to a change in the functional profile of certain entities. This can raise complex local taxation and transfer pricing issues.
Forvis Mazars’ Transfer Pricing experts will provide you with an overview of the regional/local applicable regulations and their practical recommendations in order to handle these reorganisations properly.
Agenda:
Speakers:
Moderated by: Gertrud Bergmann, Partner at Forvis Mazars Germany
4. Transfer pricing regulations related to DEMPE - 15 July 2021, 14:00 CET
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With the rise of new technologies, more and more subsidiaries are involved in the value creation of intangible assets. Before the introduction of the DEMPE functions, the profit from intangible assets was attributed to the entity that owned the property rights. From now on, the profits linked to the exploitation of an intellectual property right are no longer reserved to the owner. They are shared among the subsidiaries that perform the DEMPE functions. Forvis Mazars’ Transfer Pricing experts will provide you with an overview of the regional/local applicable regulations and their practical recommendations on the subject.
Agenda:
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