Transfer Pricing in Tax Blog
- Select a blog category
Join our next Transfer Pricing webinar: Year-end transfer pricing adjustments on 1 December at 3pm (CET)
Join our next Transfer Pricing Webinar on 1 December at 15.00 CET to discuss the considerations and potential implications associated with year-end transfer pricing adjustments, tax authority developments in this area, including how MNCs are managing this process, and the related tax implications.
About the Webinar
As we approach year-end, many companies are reviewing their transfer pricing results and evaluating the potential need for year-end transfer pricing adjustments for certain intercompany tangible goods, services, and royalty transactions. In this webinar, we will explore when transfer pricing adjustments are typically needed, as well as the various legal, regulatory, and tax considerations for making year-end adjustments. We will also discuss recent tax authority developments in this area and provide an industry perspective on this topic.
Deloitte’s 2020 global BEPS survey on the OECD’s Base Erosion and Profit Shifting (BEPS) initiative and the next wave of Global Tax Reset provides valuable insight into the strategies of some of the world’s largest multinational companies in the face of changes to the international tax framework. The survey gauges the attitudes of multinational and Swiss tax leaders towards the expected impact on their organisations of increased media, political, and activist group interest in tax and investigates how multinationals are addressing the impacts of the OECD’s Pillar One and Pillar Two projects and the challenges of a changing global tax landscape.
On 12 October 2020, the G20/OECD Inclusive Framework on BEPS (“inclusive framework”) released two detailed “blueprints” in relation to its ongoing work to address the tax challenges arising from the digitalisation of the economy. The Pillar Two blueprint proposes a set of interlocking international tax rules designed to ensure that large multinational businesses pay a minimum level of tax on all profits in all countries. Comments on the blueprint are invited by 14 December 2020 and a virtual public consultation meeting will be held in January 2021.
On 12 October 2020, the G20/OECD Inclusive Framework on BEPS released two detailed ”blueprints” in relation to its ongoing work to address the tax challenges arising from digitalisation of the economy. The Pillar One Blueprint, which is discussed in this Tax Blog, sets out “building blocks” for potential future international agreement on rules for taxable presence (nexus) in countries and profit allocation between countries to address tax challenges arising from digitalisation. Our comments on the Pillar One Blueprint and our view of what Swiss companies should do, can be found at the end of the blog.
The Swiss federal tax authorities have introduced a new portal for the submission of Country-by-Country Reporting (CbCR) in Switzerland. Together with the introduction of the portal the Swiss tax authorities have published certain updates to the guidance and announced that from 1 February 2021 CbCRs will need to be submitted in the OECD XML-Scheme 2.0.
In the wake of the COVID-19 pandemic, organisations are speeding their move to cloud-based ERP solutions—and leaders are increasingly recognising the importance of seating tax at the planning table.
As the COVID-19 crisis has made crystal clear, agility is key to survival in the face of disruption. Those organisations foresighted enough to have digitised, automated, and cloud-enabled their back-office processes have been able to pivot toward recovery. Those still pushing paper and working with on-premise systems have struggled. In a matter of weeks, the benefits of cloud-based back-office environments became painfully obvious.
On February 11, 2020, the Organisation for Economic Cooperation and Development (“OECD”) issued the final version of the Transfer Pricing Guidance on Financial Transactions (the “FT Guidance”).
Although tax and transfer pricing professionals had started to digest the implications of the Guidance and to implement relevant changes relating to financial arrangements, the momentum was very quickly interrupted by the onset of the COVID-19 virus and the resulting economic impact for many sectors within the global economy.
Transfer Pricing Webinar on 25 August 2020: (L)IBOR Transition and Intra-Group Financing – Transfer Pricing Aspects of an Unprecedented Transformation
The Transfer Pricing Webinarwas hosted on Tuesday, 25 August 2020, 10.00am (CET) to discuss recent developments on the upcoming (L)IBOR transition and the resulting implications from a transfer pricing perspective.
About the webinar:
Interbank Offered Rates (IBORs) such as LIBOR (London Interbank Offer Rate) are deeply rooted in the financial system. They are estimated to underpin USD 350 trillion of financial products (e.g. bonds, derivatives, loans, mortgages) and serve as the basis for many contracts and valuations.
On 18 June 2020, the OECD Secretary-General issued a statement regarding recent statements and exchanges in relation to the ongoing negotiations to address the tax challenges of the digitalisation of the economy. Most notably in this respect is that the United States seem to have sent a letter to certain European countries (France, Italy, Spain and the UK) warning them that the discussions regarding the OECD’s Taxing the Digital Economy initiative has reached an “impasse” and that the US will put retaliating measures in place when these countries press ahead with the local implementation of Digital Service Taxes (DSTs).