TPA Global Webinars 2017

TPA Global Webinars 2017
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TPA Global Webinars 2017
July 26th, 2016
Transfer pricing in Hungary and Romania
A readiness check on whether your Romanian and Hungarian subsidiaries are fulfilling the local transfer pricing requirements

Transfer pricing in Hungary and Romania

A readiness check on whether your Romanian and Hungarian subsidiaries are fulfilling the local transfer pricing requirements

Transfer pricing is a hot subject for companies operating in Romania and in Hungary. This is because the local tax authorities are focusing more on this topic, with the number of transfer pricing audits increasing significantly in the last few years.

The Romanian transfer pricing legislation was updated in 2016. Although the changes were triggered by the BEPS action plan, not all the provisions of Action 13 were implemented. The new provisions of the transfer pricing legislation impact in particular the category of large taxpayers. The companies include in this category must prepare the local transfer pricing report by the time the corporate tax return is submitted. This measure has put an increased pressure on these companies which sometime struggle with the availability of information.

In Hungary the topic has been in the focus for many years. Hungarian tax payers have to face with many tax audits that is why lots of experience is gathered. During the webinar we will provide an update on the Hungarian TP related requirements and we will share our experience gained during tax audits and court cases where Sándor Szmicsek was invited to be a tax expert witness.  

The webinar will consider the following:

  1. General presentation of Romanian transfer pricing legislation, including the changes applicable for 2016.
  2. The main transfer pricing risks faced by companies operating in Romania.
  3. Practical experience of transfer pricing audits in Romania
  4. Update of the Hungarian transfer pricing legislation including the actions Hungary has taken after (in the course of) OECD BEPS related programs
  5. Practical experience of transfer pricing audits and court cases in Hungary

Speakers

Thursday, May 11, 2017

10:00 AM - 11:00 AM Mexico, USA and Canada
4:00 PM - 5:00 PM London (GMT)
5:00 PM - 6:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow (MSK)

Register now



The implementation of BEPS Action Plan 13 in LATAM

Tax administrations and international economic organizations have reached consensus for implementing international measures that will promote tax transparency amongst the business community.

In this sense, OECD’s BEPS Action Plan 13 addresses ‘Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting’. The aim of this Action Plan is to enhance transparency for tax administrations by providing them with adequate information to conduct transfer pricing risk assessments and examinations. To tackle these issues, Action Plan 13 introduced a four-tiered approach that should allow tax administrations to compile relevant data on how multinational companies allocate taxable revenues and liabilities across the various countries where they operate:  Tier 1) a Masterfile, Tier 2) a Local file, Tier 3) Country by Country (CbC) Reporting and Tier 4) Local transfer pricing forms.

Only a few countries in Latin American (LATAM) have effectively implemented these four layers of transfer pricing documentation (Mexico, Colombia), whereas others are in the process of implementing them (Peru, Uruguay, Argentina), and others have only implemented one layer (the CbC Reporting – Chile and Brazil). However, other countries in LATAM have local transfer pricing documentation requirements which already contain some of the elements which are required by Action Plan 13. Considering these facts, what can be expected from these countries and from other LATAM countries in the context of Action Plan 13?

This webinar will be presented in English and in Spanish. 

The webinar will consider the following:

  • To which extent has Action Plan 13 been implemented by each of the LATAM countries?
  • In the countries where not all of the four layers of transfer pricing documentation have been implemented, are there local transfer pricing documentation requirements which already contain elements of Action Plan 13?
  • Regarding the countries where not all of the four layers of transfer pricing documentation have been implemented, how are these countries responding to this? Is it expected to see an implementation of Action Plan 13 in the (near) future?

At the end of the web event, you will:

  • Understand which LATAM countries have implemented the documentation requirements of Action Plan 13, and to which extent – i.e., whether all the four-tiers were implemented.
  • Identify the LATAM countries that have local transfer pricing documentation requirements which already contain elements of Action Plan 13, despite of no formal adoption of Action Plan 13.
  • Realise how LATAM countries are responding to Action Plan 13, if a future implementation of this Action Plan is expected, and the expected date of implementation of Action Plan 13 in the various LATAM countries which have not done it yet.

Speakers 

  • Belisa Severini, Senior Associate, Transfer Pricing Associates, Argentina.
  • Rita Botelho, Associate, Transfer Pricing Associates, The Netherlands.
  • Jose A. Otero, Partner at TPS, TPA Global Member.
  • Esperanza Buitrago, Associate Professor Tax Law Department Maastricht University, The Netherlands.

Thursday, June 8, 2017

Spanish version 
10:00 AM - 11:00 AM Mexico, USA and Canada
4:00 PM - 5:00 PM London (GMT)
5:00 PM - 6:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow (MSK)

Registrarse

Monday, June 12, 2017

English version
10:00 AM - 11:00 AM Mexico, USA and Canada
4:00 PM - 5:00 PM London (GMT)
5:00 PM - 6:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow (MSK)

Register now



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TPA Global Webinars 2017
; posted on
July 26th, 2016
Transfer pricing in Hungary and Romania
A readiness check on whether your Romanian and Hungarian subsidiaries are fulfilling the local transfer pricing requirements
Value Chain Analysis Workshops for Corporates

Join us at one of our Value Chain Analysis Workshops in Amsterdam and Singapore for global Corporates.

  • Implications of BEPS
  • Requirements for BEPS
  • VCA techniques
  • Strategic Impact of a VCA
  • Governance and Control Impact
  • Alignment of Business Operating and TP Operating Model

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