Transfer Pricing of MNEs is the most important issue in International taxation. As an essential tool of tax planning for a MNE, its methods and approaches are under the strict scrutiny of tax authorities globally. Because of such scrutiny, this webinar will also discuss the best practices associated with compliance, especially in light of the additional requirements the OECD BEPS initiative mandated.
The BEPS initiative consist of fifteen articles, five of which focus on transfer pricing. This initiative’s purpose was to stem the tide of base shifting between countries due to “loopholes” in the International Tax system. The Transfer Pricing BEPS articles focus on methods, documentation and dispute resolution and are designed to create a common approach to MNEs global transfer pricing compliance.
This webinar lays a clear-cut foundation for understanding commonly applied methods and best practices for compliance. After this, the discussion turns to the impact of layering BEPS requirements on top of the basics of transfer pricing practice.
Publication Date: July 2021
Designed For
Essential for all practitioners who deal with cross-border tax compliance and planning issues — and is especially important today as the IRS has aggressively increased scrutiny and enforcement activity in the international tax area.
Professionals in public practice and in industry will benefit from this program. Business tax and finance executives, directors, managers, and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys and financial advisors who work with and advise businesses and individuals that have cross-border operations, activities, and issues.
Topics Covered
- Intra-group transactions
- The Arm's-Length Standard
- Formulary apportionment
- Methods
- Documentation requirements: Master file, Local file, and Country by Country ("CbCr) report
- Impact on Business due to BEPS
- Dispute Resolution aspects of BEPS
- Treaty aspects of BEPS
- Policy aspects of Transfer pricing under BEPS
- Meaning of transfer pricing outcomes better aligned with value creation of the MNE group.
- How the role of capital-rich, low functioning entities in BEPS planning will become less relevant.
Learning Objectives
- Describe BEPS basics
- Recognize and apply the US Transfer Pricing Guidelines
- Recognize OECD Transfer Pricing Guidelines and BEPS
- Describe BEPS updates to global transfer pricing: Actions 8-10
- Recognize how BEPS Article 13 emphasizes Tax Authority risk assessment
- Identify new documentation requirements after BEPS
- Recognize the importance of CbCr report from Article 13
- Identify one of the BEPS concerns which harm business
- Recognize which type of report contains information regarding the allocation of income, taxes, and business activities per jurisdiction
- Identify the number of principle documents that are required to fulfill contemporaneous documentation requirements
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (1 hour)
Program Prerequisites
None
Advance Preparation
None
Instructor
William J. Seeger
William J Seeger, Ph.D., MJUR is currently Clinical Full Professor of Economics at the University of Texas at Arlington, College of Business Administration, and President of QuantEcon Consulting, an Economic consulting firm. The focus of his academic research is Transfer Pricing and International Tax issues. Upon his retirement in October, 2014, Dr. Seeger was a Principal in KPMG’s Global Transfer Pricing Services practice. He was practice leader, Economic and Valuation Services, for the Dallas, Houston and Denver Business Units and a senior economist and Southwest area lead for KPMG’s Economic Consulting Practice. Dr. Seeger has twenty years of experience in public accounting and three years’ experience with the Internal Revenue Service as an Industry Economist in the Comprehensive Examination Program.