Nupur Jalan’s Post

Asymmetric Profit Splits in Transfer Pricing. I’ll be very interested to hear your views and experiences on this. In relation to the application of the Transactional Profit Split Method, the OECD Transfer Pricing Guidelines comment as follows (at para 2.115): “References to “profits” in this section should generally be taken as applying equally to losses. That is, where a transactional profit split method is determined to be the most appropriate method, it should generally also apply, and apply in the same way, regardless of whether the transaction(s) result in a relevant profit or loss. Asymmetrical splits of profits and losses (i.e. where the parties apply different considerations depending on the results of the transaction) might be arm’s length, but should be used with caution and appropriately documented.” In other words, the default position is that losses should be shared in the same proportions as profits – but that asymmetric arrangements may be justifiable. Any such arrangements should be documented in the relevant intercompany agreement, which should be entered into in advance. What situations and justifications for asymmetric treatment of profits and losses have you utilized or come across? One may be that the entities making unique and valuable contributions may have different capacities to assume risk / bear potential losses. But I’m sure there must be others. #TransferPricing #LegalSubstance #IntercompanyAgreements

The introduction of Base Erosion and Profit Shifting (BEPS) initiatives has fundamentally altered the landscape for multinational enterprises (MNEs). With the onset of BEPS 2.0, the terrain has grown even more intricate, posing significant obstacles for businesses worldwide, especially in the domain of transfer pricing. Deciphering BEPS 2.0: BEPS 2.0 is designed to combat tax avoidance by ensuring that MNEs pay taxes in jurisdictions where economic activities and value creation occur. Introducing measures like Pillar One and Pillar Two, BEPS 2.0 fundamentally reshapes transfer pricing principles, necessitating a re-evaluation of traditional approaches. Key Challenges in the BEPS 2.0 Landscape: From the convergence of tangible assets and intangible value creation to the implementation of a global minimum tax, BEPS 2.0 presents myriad challenges for tax professionals involved in transfer pricing. Addressing Transfer Pricing Challenges Strategically: To align with BEPS 2.0 guidelines, tax heads must conduct thorough risk assessments, implement robust policies, and adopt advanced methodologies. Proactive engagement with tax authorities and leveraging technology are essential for resolving disputes and ensuring compliance. Leveraging Technology for Enhanced Transfer Pricing Analysis: In navigating the complexities of BEPS 2.0, technological advancements and data analytics are indispensable. Automated tools streamline compliance processes and facilitate the preparation of transfer pricing documentation. For further insights, kindly read our detailed blog post: https://lnkd.in/efuGS6Vm Preeti Sneha

Dive into the dynamic world of transfer pricing and Intangibles with our comprehensive course covering key topics like IP in global value chains, attribution of intangible returns, hard-to-value intangibles, and more! Elevate your skills by mastering the six-step analytical framework, identifying intangibles for transfer pricing, applying the DEMPE concept and navigating regional and sectoral challenges. Stay ahead and join us to unravel the intricacies of intangibles and enhance your expertise in this evolving field: https://lnkd.in/eJYWDBUh hashtag #TransferPricing hashtag #TransferpricingIntangibles hashtag #IBFD hashtag #internationaltax hashtag #onlinecourse

Transfer pricing is not just about adjusting transactions; it's a multifaceted strategy that shapes your business identity. 🤝 Your business conduct and partnerships speak volumes about your entity, emphasizing the need for trust on a global scale.💼✨ Let's find out how Transfer Pricing can be the cornerstone of global trust-building. 👇 💱 Steering clear of tax evasion and profit-shifting isn't just about compliance; it's a commitment to a stellar reputation and unshakeable trust in your management. 🔎 Ensure that transactions between related entities mirror market conditions, creating a level playing field where Multinational Corporations can compete with flair. ⚖ Embrace timely adherence to regulatory requirements, minimizing the risk of audits, penalties, and assessments, preserving your business reputation. 📃 Fair transfer pricing practices act as a bulwark against double taxation. Transparent documentation and methodologies provide authorities with the clarity needed to endorse your pricing decisions. 🌏 Align your Transfer Pricing policies with international standards like OECD guidelines. This not only maintains uniformity but also fosters global collaboration, showcasing your commitment to best practices. Trust isn't just earned; it's meticulously built through ethical conduct and a commitment to global standards. #TransferPricing #EthicalBusiness #GlobalTrustMatters #OECD

Let's explore tips for Transfer Pricing Success! Today, having solid transfer pricing documentation is crucial due to changing rules. Here are key ways to make it happen: Firstly, understanding the rules at different places is key. This lays the groundwork for good documentation and compliance. Secondly, thorough checks on all intercompany transactions help spot pricing issues early. Thirdly, ensuring your documentation aligns closely with OECD guidelines is crucial. Fourthly, teamwork between the finance, tax, and legal teams is essential for success. Lastly, staying vigilant with regular risk checks prevents problems down the line. Do you have any insights to add? Share in the comments! #TransferPricing #TaxCompliance #FinancialStrategies

❓Transfer Pricing regulation changes – are you affected? ➡UK members of multinational groups with at least €750 million in revenues for the relevant period must now prepare transfer pricing documentation according to a prescribed format. The key changes include: 🕘 Timing 📃Provision of records to HMRC 📎 Preparation a master file ✔ Discover the full list of changes here - https://lnkd.in/gHVSNMup

From a transfer pricing perspective, some considerations are important for the cost-contribution arrangements. Firstly, there must be a clear identification of shared costs, ensuring a comprehensive understanding of the expenses involved. Secondly, aligning CCAs with established transfer pricing methodologies is vital to reflect market conditions and comply with international tax regulations. Thirdly, robust documentation practices are essential, maintaining detailed records of the agreement terms, cost-sharing rationale, and applied pricing methods. Fourthly, a balanced allocation of risks and rewards among entities is necessary for a fair distribution of benefits. Lastly, adaptability to evolving business dynamics is crucial, requiring regular reviews and adjustments to the agreement in response to market or business changes. In summary, effectively managing CCAs and transfer pricing is key for MNEs to achieve financial optimization and maintain regulatory compliance. #CostContributionAgreements, #TransferPricing, #MultinationalEnterprises, #FinancialManagement, #TaxCompliance, #RiskManagement, #BusinessCollaboration, #MarketConditions, #InternationalBusiness, #EconomicStrategies. https://lnkd.in/eZaRmq3r

Demystifying Transfer Pricing. Credit post: Bojan Radojicic - give him a follow! All essential Transfer pricing facts and insights in one place. Let’s your TP knowledge begin here. 🚀 𝗛𝗲𝗹𝗽 𝗺𝗲 𝘀𝗵𝗮𝗿𝗲 𝘁𝗵𝗶𝘀 𝗲𝘀𝘀𝗲𝗻𝘁𝗶𝗮𝗹 𝗶𝗻𝘀𝗶𝗴𝗵𝘁𝘀 𝘄𝗶𝘁𝗵 𝘁𝗵𝗶𝘀 𝗙𝗥𝗘𝗘 𝗖𝗵𝗲𝗮𝘁 𝗦𝗵𝗲𝗲𝘁. 🧿 𝗛𝗲𝗿𝗲 𝗶𝘀 𝘄𝗵𝗮𝘁 𝘁𝗵𝗲 𝗧𝗿𝗮𝗻𝘀𝗳𝗲𝗿 𝗣𝗿𝗶𝗰𝗶𝗻𝗴 𝗖𝗵𝗲𝗮𝘁 𝗦𝗵𝗲𝗲𝘁 𝗜𝗻𝗰𝗹𝘂𝗱𝗲𝘀: ▶️ Related parties’ determination ▶️ Local TP file content ▶️ Master TP file content ▶️ Arm’s length principle explained ▶️ Example of related parties’ transaction list and table ▶️ TP value chain ▶️ Comparability factors ▶️ TP risk indicators by OECD ▶️ Functional analysis example ▶️ Comparability analysis example ▶️ TP methods list ▶️ TP methods explained ▶️ List of criterion for application and selection appropriate method ▶️ TP databases ▶️ TP & Statistics ▶️ Interquartile range and median calculator example ▶️ How to apply database filter ▶️ 14Steps to perform TP benchmarking analysis ▶️ Profit level indicators and formulas Follow Long Term Mindset for more content like this. *** P.S. Want to master the basics of accounting (for free)? I created a 5-day, email-based course that explains the Balance Sheet, Income Statement, and Cash Flow Statement in plain English. Check it out here (It's free) → https://lnkd.in/eKbRV7g6 If you found this post useful, please repost ♻️ to share with your audience

Need an update on global and Norwegian developments for Transfer Pricing? Sign up for the seminar in Oslo next week, see Nick Pearson-Woodds post below for more information and registration 👇 #transferpricing #taxoperate

🔍 Transfer Pricing 101: Concepts, Methods, and Compliance In today's global business environment, transfer pricing plays a crucial role for multinational corporations. It's more important than ever to understand the key concepts and methods to ensure compliance and manage tax risks effectively. In my latest YouTube video, I cover: What is Transfer Pricing? Understand the basics and its impact on cross-border transactions. - Transfer Pricing Methods: From CUP to Resale Price, I explain the methods and when to use them. - Compliance and Documentation: Discover the importance of proper documentation and how to stay compliant with international and local regulations. -Best Practices: Learn how to develop a strong transfer pricing policy that minimizes risks and aligns with business goals. -Whether you're a tax professional, finance expert, or business owner, this video is packed with valuable insights! 📽️ Watch the full video here: https://lnkd.in/dW-e-WER 💬 Let me know your thoughts in the comments or feel free to ask any questions! If you find this video useful please subscribe to my channel #TransferPricing #InternationalTaxation #Finance #TaxCompliance #Business #Accounting