TPA Global Webinars 2017

90 days and the time is ticking!

10 Practical Tips to Manage (tax risk) and File your Country-by-Country Report before year end!

No other Action of the OECD’s 15 Action Points will have wider consequences than Action 13 – Guidance on Transfer Pricing Documentation and Country by Country Report” – in terms of the data ammunition provided to tax authorities to perform tax risk assessment!

After issuing various guidance and handbooks since the roll out of the Final BEPS Action 13 in 2015, the OECD last week published additional guidance to BEPS Action 13: Handbook on effective tax risk assessment. This publication will assist tax authorities in carrying out tax risk assessment before embarking on a full-blown tax audit of the taxpayer.

Most likely, with or without the assistance of tax technology, you must have already produced your first draft Tables 1, 2, and 3 of your Country-by-Country Report (CBC Report) and analyzing them as part of your own assessment of BEPS related risks. Apart from analyzing various financial ratios of the data in Table 1, and the information in Table 2 & 3, you will have to considerer the “dotted lines” that might be connecting the CBC Report with the other sources of information, such as Masterfile, local files, TP forms, and tax return.

With the above background, TPA Global is pleased to conduct a webinar on this crucial topic of CBR Report. The webinar will cover the following 10 practical topics:

  1. What are the important visual data analysis tools I should be using to detect BEPS tax risk and the ‘false +ves’ (no BEPS tax risk)?
  2. A practical case study on how a CBC Report should be analyzed.
  3. What quick steps I should take to mitigate any potential BEPS risk in my CBC Report?
  4. How to ensure my legacy tax positions not becoming dragged in the post BEPS world?
  5. Should I be proactive or reactive in my communication to tax authorities on the analysis outcome of the CBC Report, i.e. what is the role of Table 3?
  6. What is the most relevant tax technology tool to manage my tax risk in a CBC Report?
  7. How to convert the big data in a CBC Report into an opportunity, for example, by performing a high-level value chain analysis?
  8. How to get a buy-in from the key stakeholders on the business and tax changes suggested by the outcome of the CBC Report risk analysis?
  9. How to manage corporate tax governance in case there are too many BEPS tax risks?
  10. What quick organization changes I should be making to remain in control of my CBC Report risk assessment process, i.e. how does my multiple year approach look like?

Speakers

Steef Huibregtse
Managing Partner, TPA Global
The Netherlands
Virender Sharma
Partner, TPA Global
The Netherlands
Victor Denekamp
Associate, TPA Global
The Netherlands
     

Thurday, 12 October, 2017

Thursday, 19 October, 2017

10:00 AM - 11:00 AM Mexico, USA and Canada
2:00 PM - 3:00 PM Brazil
4:00 PM - 5:00 PM London (GMT)
5:00 PM - 6:00 PM Amsterdam (CET)

Register
9:00 AM - 10:00 AM Mexico, USA and Canada
1:00 PM - 2:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)

Register

 



New transfer pricing regulations in Poland in force since January 1st, 2017

  • New transfer pricing regulations in Poland were introduced into the tax system to implement the instruments developed by OECD within BEPS framework. However, there are some different items and obligations included in Polish regulations that are not part of the OECD Guidelines.
  • Lawmaking activity in the field of transfer pricing is followed by an increasing number of transfer pricing audits launched by Polish tax authorities.
  • The Ministry of Finance initiates various activities to ensure effective tax audits:
    • Establishing units specialized in transfer pricing issues,
    • Engaging highly experienced specialists, and
    • Providing tax authorities with an access to commercial databases.
  • Significantly expanded obligations in the field of transfer pricing comprising:
    • Preparing transfer pricing documentation (Local file and Master file),
    • Preparing benchmark analysis,
    • Filing additional documents, e.g. simplified statement on transactions and other occurrences between related entities (CIT-TP), Country-by-Country Report, Country-by-Country notification,
  • Obligation to prepare transfer pricing documentation depends on these factors: (i) the level of revenues or costs generated by the taxpayer and (ii) the value of transactions made with related entities.
  • The minimum obligation to prepare transfer pricing documentation at the local level applies if revenues or costs generated by taxpayers exceed a threshold of EUR 2,000,000.
  • One of the challenges some taxpayers are facing is the obligation to prepare Country-by-Country notification - deadline for filing the first Country-by-Country notification is October 31st, 2017.

The scope of the transfer pricing obligations since January 1st, 2017 is more extensive than that of previous years, so meeting the new obligations may be a complicated and time-consuming process. Therefore, it is recommended to verify potential obligations in the field of transfer pricing for your company and launch appropriate works as soon as possible.

The webinar will address:

  1. Summary of Polish transfer pricing legislation in force since January 1st, 2017.
  2. Obligation to prepare benchmark analysis in Poland.
  3. Simplified statement on transactions and other occurrences between related entities (the so-called CIT-TP).
  4. Country-by-Country reporting according to Polish regulations.

Speakers

Magdalena Marciniak
Senior Manager and Head of Transfer Pricing Team
MDDP Michalik Dłuska Dziedzic i Partnerzy spółka doradztwa podatkowego sp. z o.o.
Poland

Marta Klepacz
Senior Consultant
MDDP Michalik Dłuska Dziedzic i Partnerzy spółka doradztwa podatkowego sp. z o.o.
Poland

Thursday, 16 November, 2017

9:00 AM - 10:00 AM Mexico, USA and Canada
1:00 PM - 2:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow

Register



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