Forvis Mazars BEPS & international tax newsletter
Each month, find out about regulatory developments, particularly in relation to the introduction of the OECD's BEPS initiative, which could impact your tax obligations in the short or medium term.
Transfer pricing
A global view on a business-critical, fast-evolving issue
Organisations that span international borders are increasingly facing complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is at the top of the tax priority list for many mid-sized and large businesses, with an outsized impact on and business units. We offer a range of solutions for transfer pricing management so you can ensure compliance with local regulations.
Our approach
There is greater scrutiny of transfer pricing the world over. Only a global, multi-layer approach can bring simplicity to this fast-evolving issue. Our global partnership in more than 90 countries provides the vital expertise in tracking developments such as new legislation and court/tribunal rulings in each jurisdiction, through direct contact with our transfer pricing experts who have deep industry know-how and the local and international expertise necessary.
Our International Transfer Pricing Community brings together specialists from across disciplines, including economists to help with value chain analysis: a vital tool to align transfer pricing with economic value creation and establish transfer prices for intangibles. Data is the foundation for a robust transfer pricing regime. Recognising this, we have created databases and tools such as a cloud-based system to ease reporting under the EU’s DAC6 directive.
Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as exposure. We then work closely with you to make sure you can meet your documentation obligations and optimise your tax positions.
Our services
- Strategic advice on all aspects of transfer pricing
- Master file, local file and country by country reporting
- Tax audits, mutual agreement procedures
- Value chain analysis and transformation
- Economic analyses, including commercial benchmarks, loan benchmarks, and license benchmarks
- Cash pools and other integrated group wide financing systems
- Transfer of functions, valuation of transfer packages, exit taxation
- Valuation of hard to value intangibles
Our tools & solutions
With Transfer Pricing Genie, we offer a digital transfer pricing documentation solution that is a more efficient approach to increase transfer pricing processes. We also offer database access, including Bloomberg and RoyaltyStat, as well as the automatic transmission of country by country reports (CbCR) and data exchange through our Signals tool.
Our people
Our team consists of experienced tax specialists and transfer pricing experts with country and sector specific tax and industry knowhow, accountants and economists, which ensures that we can provide, develop and implement customised transfer pricing solutions that fit with our clients’ commercial and tax strategies.
Explore further
DAC6
The DAC6 Directive (EU) 2018/822 requires EU Member States to impose compulsory reporting obligations on intermediaries and taxpayers in relation to cross-border tax arrangements. Here you will find all the information you need about the regulatory framework, the challenges involved and our portfolio of DAC6 services
The impact of inflation on transfer pricing
The economic impact of inflation has considerable consequences on transfer pricing for multinational entities (MNEs). Combined with the Covid-19 crisis and the war in Ukraine, rising inflation adds further complexity to the management of transfer pricing policies for MNEs.
Webinar: Transfer pricing trends in Asia
As the tax landscape continues to evolve, transfer pricing remains a top priority for multinational enterprises. In this webinar, our experts will present you with the latest transfer pricing trends in Asia.
Webinar: tax impact of the war in Ukraine
Join our latest global webinar, dedicated to the tax impact of the war in Ukraine on multinational enterprises (MNEs).
TP aspects of intragroup loans and guarantees
March 25, 2021 – 14:00 CET Join us on a webinar dedicated to the overview of the transfer pricing aspects of intragroup loans and guarantees. Our specialists will help you understand the main points presented in the OECD transfer pricing guidance on financial transactions.
Prix de transfert des transaction financières
Jeudi 18 mars | 11h-12h Mazars organise un webinar dédié aux prix de transfert des transactions financières. Nos experts vous apporteront un décryptage des bonnes pratiques à suivre en la matière, notamment dans le cadre des financements intragroupe.
The impact of the economic crisis on TP
An analysis of the impact the economic crisis in 2022 has had on global transfer pricing.
Are you ready for LIBOR transition?
05/05/2021 Regulators kicked off the final countdown for the London Interbank Offered Rate (LIBOR) on 5 March 2021. The U.K. Financial Conduct Authority confirmed that the final fixings for most LIBOR rates will take place at the end of this year, with just a few key dollar tenors set to live on for a further 18 months.
Overview of the transfer pricing documentation
The OECD has long attempted to create a harmonized playing field for transfer pricing documentation, although countries have only recently started to apply a more consistent approach based on the recommendations provided.
UK proposes to formally adopt OECD's Masterfile
As part of UK ‘Tax Day’ on 23 March, the UK government announced its proposal to formally adopt OECD BEPS Action 13, a three-tiered approach to transfer pricing documentation to encourage a global standardised approach that multinational businesses would be expected to follow, as a mandatory requirement.
Covid-19 Transfer pricing comparability analysis
15/02/2021 The recent publication of the Organisation for Economic Co-operation and Development (OECD) provides us with generic guidance on how to handle comparability analysis during the pandemic period. However, the lack of practical guidelines from the OECD forces us to ask ourselves what approach should be taken.
The OECD's guidance on transfer pricing
The OECD released its guidance on the transfer pricing implications of the Covid-19 pandemic on 18 December 2020.
Transfer prices in times of COVID-19
During this global pandemic, companies should urgently review their existing transfer pricing models in order to reassess transfer pricing risks, take appropriate countermeasures in the short term and find efficient solutions for compliance.
The impact of Covid-19 on transfer pricing
22/10/2020 The Covid-19 pandemic has far-reaching consequences, and will have serious implications on transfer pricing for many multinational enterprises (“MNEs”). This is particularly challenging for businesses to manage due to the current lack of guidance from the OECD.
Transfer Pricing databases from Mazars
Rapid, online identification and comparison of Transfer Pricing regulations in more than 50 countries collected by Mazars.
Contact
Teja Paulin Partner, Tax Advisory - Ljubljana
Webinar playback on deployment of digital service
During the webinar on 23 February 2021, Mazars’ experts from Europe and Asia talked about the latest developments in the field of digital service taxes with a special focus on the legislations in place in European countries and their consequences for multinational companies.