Value Chain Analysis (VCA)
Save The Date - TPA Global VCA Workshop for Corporates
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March 9th, 2017
“Value Chain Analysis Workshop for Corporates in Amsterdam, Singapore and New York - The Bridge to Align the Operating Model, Corporate Governance Framework and the Tax/Transfer Pricing Structure of a MNE”
Due to globalization and increasing business complexities, management boards are experiencing difficulties in being in control of their operating model and transfer pricing model simultaneously. The key decision makers in an organization in practice appear sometimes wearing multiple hats in the decision-making process, making the organization not being in control.
The Australian Treasury Published Submission From DPT Consultation
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March 5th, 2017
The Australian Treasury published 21 submissions received on the exposure draft legislation for a Diverted Profits Tax (DPT), which was launched by the Australian Government on November 29.
Background: DPT
Value Chain Analysis – the bridge between operating, governance and tax/TP models of an MNE
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February 9th, 2017
Value Chain Analysis has become a burning topic for discussion for many after the publication of the final report on BEPS Action Plan 13 and subsequent notifications by governments (especially the Chinese government) on the extent of information to be included in such analysis. Due to lack of consistent and clear guidance on what triggers the need for a value chain analysis, what a value chain analysis should entail, how the value chain analysis will be used by tax authorities around the globe etc.
Valuation Services after BEPS
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January 24th, 2017
Apart from being a crucial tool for businesses for placing a value on their business to be used in case of sale of a business, partnership dissolution, mergers and acquisitions, loan/financing arrangements, the importance and need for valuation has been further strengthened by the OECD under BEPS Action Plans 8 – 10 by stating that valuation techniques may be used as a part of one of the five OECD approved transfer pricing methods. In situations where reliable comparable uncontrolled transactions for a transfer of one or more intangibles cannot be identified, it may also be possible to use valuation techniques to estimate the arm’s length price for intangibles transferred between associated enterprises.
VCA – A Bridge To Align Operating And Governance Models With Tax/TP Set-up
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January 24th, 2017
The value chain refers to the entire performance process of a company, which begins with the research and development and ends with the delivery to the end consumer. While a functional and risk analysis is geared to individual group companies, a value chain analysis applies on crosscompany processes within the Group.
EU Commission Publishes The Apple Case Decision
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December 20th, 2016
The EU Commission has published the non-confidential version of the final negative decision adopted on 30 August 2016 concluding that Ireland gave illegal tax benefits to Apple, worth up to €13 billion.
Background
ATO Welcomes Comments on Diverted Profits Tax
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December 1st, 2016
On November 29, the Australian government released draft legislation for implementation of the Diverted Profits Tax, designed to identify large multinationals seeking to avoid tax by shifting profits and will impose a penalty tax rate of 40 percent.
Background: DPT
Value Chain Analysis (VCA) 'Survival Kit'
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December 1st, 2016
The year 2016 has been a bumpy ride for many corporations having to tackle multiple conflicting unilateral regulations as the implementation of BEPS gains further stronghold across the globe.
Therefore, keeping in mind the imminent need for clarity on preventive actions to be taken by corporations, TPA Global organised a conference in Amsterdam last week on 'Value Chain Analysis - The BEPS Generation of Functional Analysis'.
Slicing the Pie - A Quantitative Value Chain Analysis
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November 23rd, 2016
Authors: Steef Huibregtse is CEO and Senior Partner and Maria Grigoryeva is Junior Associate at TPA Global.
Following BEPS publication on profit split on October 5, 2015 and July 4, 2016, MNEs are being challenged to apply the holistic view on their value chain.
China Takes the Lead on Transfer Pricing Policy: Combating BEPS Through a Value Chain Analysis
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October 29th, 2016
Authors: Steef Huibregtse is the CEO and the founding partner of TPA Global, and Ying van Galen Wang is a project manager with the firm.
China’s State Administration of Taxation on June 29, 2016 issued a new transfer pricing regulation - Bulletin 42, which replaced specific sections stipulated in previous transfer pricing circulars2 in relation to annual filing of related-party transactions and contemporaneous transfer pricing documentation.
Value Chain Analysis (VCA)
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Value Chain Analysis (VCA)
October 29th, 2016
Value Chain Analysis (VCA)
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October 29th, 2016

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