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Partner at PairFact Legal AG, triple qualified lawyer (GA, USA; Germany; Switzerland), business coach, director
Understanding Transfer Pricing Documentation: Key for Multinationals Transfer pricing documentation, comprising the Master File and Local File as per OECD guidelines, is vital for multinational corporations. It includes: -Overview of transfer pricing policies. -Detailed transaction descriptions. -Analysis supporting pricing decisions. -Benchmarking studies. -Compliance documentation. By diligently documenting these aspects, companies ensure compliance, mitigate risks, and safeguard their tax positions effectively #knowledgeshare #willeague #transferpricing WORLDWIDE INDEPENDENT LAWYERS LEAGUE Enrica Maggi Marco Buscema Joseph Weinrauch Paola Turello Malgorzata Skawinska Justyna Matuszak-Leśny, LL.M. Rashi Bansal Mark Tan David Levine Helena Sjögren Dr. Pallavi Divekar, (Ph. D) Maximilian Breitling Begüm Mermeroğlu Francesca Sperti Beatrice S. Tasca-Langer Eduardo Brenna Fritz-Gerald Morisseau Quentin Dunod Dr. Michael Lorz Stéphanie Hirsiger Anna Kriech Kathrin Dr. Cornelius Cornelius Bonnie T.
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Partner at PairFact Legal AG, triple qualified lawyer (GA, USA; Germany; Switzerland), business coach, director
Continuing my Knowledge Share series , let's talk about the transfer pricing and the challenges it faces What are the challenges in Transfer Pricing? Navigating transfer pricing can pose significant challenges for multinational companies due to regulatory complexity and documentation requirements. Regulations differ across jurisdictions, creating compliance hurdles for businesses operating in multiple regions. Detailed documentation is often essential to justify transfer pricing policies to tax authorities, requiring thorough record-keeping and analysis. These challenges underscore the importance of a comprehensive understanding and strategic management of transfer pricing to ensure compliance and minimize risks for multinational enterprises. #transferpricing #willeague #knowledgeshare #law #legalminds WORLDWIDE INDEPENDENT LAWYERS LEAGUE Marco Buscema Enrica Maggi Joseph Weinrauch Paola Turello Malgorzata Skawinska Justyna Matuszak-Leśny, LL.M. Rashi Bansal Mark Tan David Levine Helena Sjögren Dr. Pallavi Divekar, (Ph. D) Maximilian Breitling Laura Olazarán Helena Sjögren Andjelka Radovanović Jorge Marquez-San Martin Begüm Mermeroğlu Hariz Lee Damalie Tibugwisa,
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In this May 2024 Legalwise edition of “What you Need to Know with Dr Mark”, Dr Mark Pizzacalla discusses ATO audits and some of the things that you can do to help make your business “Audit Ready”. #BDO #ATOAudits #AuditReady
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CSRD Integrated into Danish Law 🏛️ We knew it was coming, and today marks the day when things got real, as we are soon halfway through 2024 and the first reporting year for CSRD ⏳ Today's integration of the CSRD into Danish legislation marks a significant shift in the reporting landscape across Denmark as key legal updates include the incorporation of the CSRD into the Auditors Act, Companies Act and Danish Financial Statements Act with the ESRS meeting the requirements of Danish Financial Statements Act §99a 📑 Now that CSRD are officially into Danish law, the eagerly anticipated updates to the implementation guidance from EFRAG can not come soon enough 🌱
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Our partners Máire Cunningham and Edward Evans were delighted to welcome members of the Irish Australian Chamber of Commerce to our office yesterday for an insightful session on legal and accounting influencing factors on investment in association with Forvis Mazars In Ireland. #beauchampslaw #IrishAustralian #legaladvice
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Lessons learnt from the World’s 1st P2 Registration🇧🇪 To our in-scope MNE friends: 1️⃣ Articulate your MNE Group Structure in WORDS. Yes, words only - no uploading of jpgs or pdfs. If a picture is worth a thousand words - imagine a group structure with 1000 legal entities 🤯 Know your UPE and IPEs, who sits on top of who, and make sure you have your TINs and legal entity classifications ready ✅ 2️⃣ Think of a name for your MNE Group! It can be boring ABC or 123 MNE Group, or code name 007, Biggest Bestest Group etc. just keep to the character limit please (256 for Belgium) 😼 3️⃣ If your Consolidated Financial Statements are publicly available, please ensure that the link to the website works 📲 (another regulatory stakeholder for the investor relations team to consider 🤓) 4️⃣ If you haven’t been in touch with anyone from the local team - it’s time to set up a coffee chat ☕️ we may need to “borrow” their emails and mobile numbers as the “local point of contact” for the registration ☎️ also they will be your future point of notification from the local tax authority so keep those coffee chats going 💬 5️⃣ We love competition, but for P2 registrations, there is no bonus or brownie points for being the first 😀. If your advisor is Andy Baik, you can be sure we will take you down the well-trodden path 👣 6️⃣ Always pray for the best, but plan for the worst 🗓️ If there is no further extension past due date (e.g. 13 July), what is the worst case scenario? A 9% surcharge on the underpaid top-up taxes in Belgium’s case. Quantify and weigh your options accordingly ⚖️ Let the real P2 Action 🎬begin! All the best, Your P2 Team 🇸🇬 Andy Baik Charis Low Chenya (Jeff) Chiu Yuh Hyo Jin Ernest Neo Note: the above are my views and may not represent KPMG Singapore ‘s position.
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Tax insurance 🤝 Transfer pricing We're excited to sponsor the ITR (International Tax Review) 's Global Transfer Pricing Forum again. Did you know that Lockton is a leader in providing tax insurance to assist companies in eliminating transfer pricing risk? Tax insurance is an ideal solution to reduce or eliminate the economic burden of historical or potential future transfer pricing tax exposure. Learn more by linking up with us at ITR or reach out directly!
We are pleased to announce ITR’s 24rd annual Global Transfer Pricing Forum USA 2024 which returns to New York on September 26. Free to attend for in-house tax professionals, you are invited to register today and join over 150 tax and transfer pricing professionals as our expert speaker panel provide you with critical insights and guidance through a host of presentations, panel discussions, Q&As and networking opportunities. http://spr.ly/6047Ydq5J Gold Sponsors - Crowe, Deloitte and White & Case LLP Silver Sponsors - Charles River Associates, Exa, Kroll, Lockton, Maisto e Associati, Optravis LLC, Pinheiro Neto Advogados and Withum Official Drinks Sponsor - LCN Legal #TPForumUS #Taxadvisors #Taxprofesionals #Taxautorities #transferpricing #ITRevents #InternationalTaxReview #Pillar2
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🌍 Navigating the intricate landscape of Transfer Pricing in Singapore is more crucial now than ever. In our latest Newsflash, we've distilled the essence of Singapore's Transfer Pricing requirements, underscoring the pivotal arm's length principle that guides equitable transactions. This insight is indispensable for every taxpayer seeking to align with both local and global standards amidst swift international developments. At PKF-CAP, we are at the forefront of providing comprehensive Transfer Pricing solutions, covering both compliance and advisory dimensions. Our expertise is tailored to ensure your transactions not only meet the current regulations but are also poised to adapt to the global shifts in Transfer Pricing practices. Let's connect and explore how Sahil Seth can elevate your Transfer Pricing strategy to the next level. Your compliance and strategic advantage in this dynamic global landscape is our priority. 🚀 #TransferPricing #Compliance #Advisory #GlobalStandards #PKF
Dear all, In the attached Newsflash, we have provided a brief and concise summary of the current Singapore Transfer Pricing requirements and the importance for all taxpayers especially highlighting the significance of the arm's length principle. Please do reach out to us for a detailed discussion on the different Transfer Pricing related services (both compliance & advisory) which PKF can offer, to ensure your transactions duly comply with the local rules & regulations as well globally accepted principles, especially considering the rapid and key Transfer Pricing developments taking place across the globe. Thanks.
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Good summary by Sophie and Sam of some of the new tweaks to the TP rules, and their potential flow on impacts
The Australian Government is proposing to retrospectively update the guidance materials relating to Australia’s transfer pricing laws to the 2022 version of the OECD Transfer Pricing Guidelines. These updates include: - updated guidance on the Transactional Profit Split Method; - new guidance on Financial Transactions; and - new guidance for tax administrations on the application of the approach to hard-to-value intangibles. Taxpayers with intra-group financing arrangements, intangible arrangements, or arrangements where Australia is a party to ‘unique and valuable’ contributions, highly integrated activities and/or shares in the assumption of economically significant risks, should review their transfer pricing policies and documentation given a likely increased focus from the ATO on these types of arrangements.
KPMG Tax Now: Australia to adopt updated OECD transfer pricing guidance
contentplus.kpmg.com.au
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