Transfer Pricing and International Tax Planning
Article – June 2018 | RoyaltyRange
The International Forum “Transfer Pricing and International Tax Planning “ invites the leaders in the transfer pricing industry to share their experience and give advice to the professionals every spring. The main focus of this year’s forum was the changing transfer pricing scenery and the impact of these changes on the industry.
Our Manager for Eastern, Central Europe and CIS, Anna Siarheichyk, gave a speech about Intangibles post-BEPS and presented the concept of DEMPE. These topics should be fully comprehended, especially when carrying out a functional analysis with DEMPE in mind. Thus, the Multinational Enterprises can guarantee that they are complying with the OECD’s guidance for determining arm’s length compensation for group entities’ functional contributions to the value of an intangible. The importance of the DEMPE analysis is amplified by the CbC reporting requirements, which would expose the mismatch between substance and intangible related returns, if any, for a tax scrutiny in the royalty paying countries.
One of the sessions was devoted to the issue of tax control and captured a lot of attention. One of the speakers, Mykola Mishin, the Head of the Transfer Pricing Audit Department of the Tax and Customs Audit Department of the State Fiscal Service of Ukraine, gave a speech about tax disputes that arise from results of inspections of controlled transactions. The speaker focused on 6 (six) main categories of tax disputes that arose after the verifications of controlled transactions and provided details on disputes over taxpayer violations of priority requirements when choosing a method. With respect to the latter, Mykola mentioned that controlling authorities employed CUP method and cost-plus method, while tax payers used method of net profit.
We are glad to be a part of the discussions about transfer pricing and we are happy that we can help tax experts to expand their knowledge in the industry and to provide the best royalty rates, loans interest rates and service fees data for their projects. Try our databases now!