Transfer Pricing in Tax and Legal blog
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The OECD has published a new, updated version of the Transfer Pricing Guidelines, which now includes the updated guidance regarding possible approaches to apply to hard-to-value intangibles, the application of the transactional profit method and new guidance on financial transactions.
New webinar date - Practical implications on the Pillar 1 & 2 policy solutions developed by the OECD
The much anticipated, updated model rules relating to Pillar 2 have now been published by the OECD on Monday, 20 December. With this in mind, we are excited to announce that our Pillar 1 and Pillar 2 webinar will take place on Wednesday, 12 January from 16:00-17:30.
On 20 December 2021, the G20/OECD Inclusive Framework on BEPS ("inclusive framework") published Tax Challenges Arising from the Digitalisation of the Economy Global Anti-Base Erosion Model Rules (Pillar Two) ("model rules"). This follows on from the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, agreed by more than 135 of its members on 8 October 2021.
Since 2017, the 141 member countries of the inclusive framework have developed a "two-pillar" approach to address the tax challenges arising from the digitalization of the economy: addressing nexus and profit allocation challenges ("Pillar One") and global minimum tax rules ("Pillar Two").
The long-awaited model rules provide more clarity on the future of a global minimum tax rate. Although the model rules have now been published and confirm the key parameters, further clarification on certain aspects is still required. Additional details shall be provided in a commentary that is expected to be published by the OECD by the end of January 2022.
This week the council of the EU adopted the position on public CbC reporting paving the way for final approval on the EU directive by the parliament in November. This implies that EU public CbCR might become reality for multinationals as early as 2023.
The International Tax Review (ITR), is a world recognised authority and publisher for tax professionals in industry, government, private practice and research and have just awarded Deloitte Switzerland with the accolades of being the Swiss Tax Firm of the Year and the Swiss Transfer Pricing Firm of the Year for the 9th time.
Public Country-by-Country Reporting (CbCR): Corporations in the EU will have to disclose their profits and taxes in future & the US parliament puts forward a similar proposal
On Tuesday evening of last week, negotiators from the EU states and the European Parliament reached a preliminary agreement on the core of the new directive on “Public Country-by-Country Reporting”. The final approval of the Parliament and the Council of Ministers is considered a formality.
Similarly, on 12 May, the US parliament had brought forward a proposal that would direct the Securities and Exchange Commission (SEC) to require large publicly traded corporations to disclose certain tax and non-tax information on a country-by-country basis.
Managing global transfer pricing documentation - Get to know Deloitte's new technology solution "TP Digital DoX" on 23 March at 3.00PM CET
Join our upcoming webinar on 23 March 2021 at 3.00pm CET to discuss the operational management of a global transfer pricing documentation and introduce Deloitte's new technology solution "TP Digital DoX".
The next generation of our transfer pricing documentation technology is here!
Evolving implications from the OECD’s Action 13 guidance are forcing businesses to find more efficient, integrated means to manage TP documentation processes. Most complex businesses are considering adopting a centralised TP documentation approach and are examining their TP on a unified, global/regional basis. Meanwhile, tax audit activity is on the rise as authorities seek to expand their tax bases.
On 18 December 2020, the OECD released Guidance on the transfer pricing implications of the COVID-19 pandemic (‘the guidance’). It focuses on how the arm’s length principle and OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (‘OECD Guidelines’) apply to issues that may arise or be exacerbated by the COVID-19 pandemic.
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.