Transfer pricing: webinar series

New international tax framework: what would be the impact on transfer pricing? - 21 October, 14:00 CET

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 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 Mazars Ireland
• Impact of Pillar 1 on transfer pricing, Ben Semper, director at Mazars UK

• Impact of Pillar 2 on transfer pricing, Erin Alexander, director at Mazars USA

Moderated by: Frédéric Barat, Partner at Mazars France

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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:

• Comparability analysis
• Losses and the allocation of Covid-19 specific costs
• Government assistance programmes
• Advance Pricing Agreements (“APAs”)

Agenda:

• How does OECD Guidelines address the impact of Covid-19 on Transfer Pricing?
• Key take-aways for 2020.
• What should MNEs need to consider for the end of 2021?
• What should MNEs do to prepare for the following years?

Speakers:

• Frédéric Barat, Partner at Mazars France
• Elisabeth Tchumburidze, Manager at Mazars Germany
• Karen Lau, Senior Manager at Mazars Hong Kong

 Moderated by: Gertrud Bergmann, Partner at Mazars Germany

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.

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:

• Applicable regulations in Latin and North America, Asia Pacific, Europe and Africa
• The potential court cases in Latin and North America, Asia Pacific, Europe and Africa
• The practice of the Tax Authorities in Latin and North America, Asia Pacific, Europe and Africa

 Speakers:

• Sahil Seth, Senior Manager at Mazars Singapore
• Carlos Burgos, Partner at Mazars Mexico
• Erin Alexander, Director at Mazars USA
• Charl Hall, Senior Manager at Mazars South Africa
• Matteo Musi, Partner at Mazars Italy

 Moderated by:Gertrud Bergmann, Partner at Mazars Germany

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. Mazars’ Transfer Pricing experts will provide you with an overview of the regional/local applicable regulations and their practical recommendations on the subject.

Agenda:

• OECD updates, Frédéric Barat 
• (North America) USA & Canada insights, Erin Alexander,
• (LATAM) Chile insights, Sophia Orbegozo
•  (Europe) France, Germany & UK, Frédéric Barat, Gertrud Bergmann and Ben Semper 
• (Africa) Morocco, Asma Charki
• (APAC) China & Hong Kong, Anthony Tam

Upcoming webinars:

• Financial transactions practical cases from a transfer pricing perspective  - 21 October 2021, 14:00 - 15:00 CET
• Transfer pricing audits: what to expect? - 18 November 2021, 14:00 - 15:00 CET
• Mutual Agreement Procedures (MAP) best practices - 9 December 2021 - 14:00 - 15:00 CET