Introduction to transfer pricing
At Quantera Global, we believe that sharing knowledge is essential and builds relationships. On this webpage, we do this by sharing transfer pricing videos of our recent Webinars. In our videos, we share knowledge on transfer pricing. But first, an introduction to transfer pricing.
Transfer pricing video
The QG academy organises webinars on a regular basis. We record these webinars and post the videos on this transfer pricing video page for you to watch them on demand. If you are interested in transfer pricing or eager to learn about it, we highly recommend our videos. Topics of these transfer pricing videos are for example “the developments”, but also “an introduction to transfer pricing”.
If you would like to receive the slides of these presentations and/or would like to be invited for our upcoming webinars, please send an email to QGacademy@quanteraglobal.com. If you would like to discuss how we can be of service to you, please make an appointment for a free consultation by phone or fill in our contact form. We are looking forward to meeting you.
Transfer Pricing attention towards financial transactions has taken a flight in recent years and has further increased after the release of the OECD Guidance on this topic in February 2020. Additionally, on 1 July 2022 the new Dutch Transfer Pricing decree was published. The main changes in this decree relate to financial transactions and have a material impact on (parts of) the practice.
Attention for and expertise on this topic has grown with tax authorities leading amongst others to more tax audits related to financial transactions. In this webinar we will bring you up to speed on the latest developments as well as an overview of the items to pay attention to for audit readiness.
Transfer Pricing documentation Coperitas
Topics covered during the webinar are:
• How to place TP documentation in the overall TP picture
• How to adopt a risk-based approach towards handling TP documentation
• Common mistakes and how to avoid them
• How to effectively organise your TP documentation process
– Central versus decentral
– Manual handling versus Coperitass
Webcast with InsurTech Queen
During the webcast, we will discuss the following topics:
• What is Transfer Pricing
• How is Transfer Pricing relevant for start-ups and scale-ups.
Click here to watch the transfer pricing video.
Transfer Pricing Developments Poland, Germany, Austria and The Netherlands:
During the webinar, we will discuss the following topics:
o Transfer pricing rules – 2 years in new regime
o Personal liability (management board members) for non-compliance
o New tax havens regulations – controversial approach
o Revised German Transfer Pricing Law and Administrative Guidance
o What’s new and how to deal with it?
o Quick comparison with developments Germany
o Political landscape and related developments
– Questions & Answers
Tax and Treasury: it takes 2 to tango:
During this webinar we will discuss the following main topics:
- Latest updates on the tax treatment of cash pooling and intercompany funding, including the main components tax authorities will assess and red flags, by Adriaan van der Heijden and Stefan Ubachs, transfer pricing specialists at Quantera Global
- Barry Ketelaar, Group Controller Europe at AS Watson, will share his views on how AS Watson has organised the cooperation between Tax and Treasury
- Practical aspects and tooling to efficiently price your cash pools and intercompany funding by Melanie Beirens from Zanders
Click to watch the transfer pricing video.
Transfer pricing developments Africa:
During this webinar, we will discuss the following main developments in certain African countries:
• Introduction of transfer pricing legislation and guidelines;
• Amendments to existing transfer pricing legislation and guidelines;
• Introduction of or amendments to BEPS Country by Country reporting guidelines
Transfer pricing implications of Brexit:
During this webinar, we will discuss the main transfer pricing developments in the UK. In particular, we will:
- present Brexit restructuring implications for a UK-based business;
- provide an update on the current focus of HMRC and the HM Treasury in the light of Brexit and COVID-19; and
- discuss post-Brexit impact and opportunities for inbound and outbound businesses.
Watch this transfer pricing video
What to expect for 2021:
During this webinar we look into our crystal ball and shed our light on the main topics for 2021. This includes:
- Recap 2020 & Outlook 2021;
- Transfer pricing in a (post-)corona year;
- Potential impact of pillar I & II on TP policies; and
- Automation and operational transfer pricing.
Transfer pricing in the Middle East and North & Central Africa:
During this webinar we discuss the main topics with respect to Transfer Pricing in the Middle East and North & Central Africa. Topics include:
- Transfer Pricing landscape of the Middle East and North & Central Africa;
- Implementation trends of Transfer Pricing legislation;
- Transfer Pricing Audit Triggers in the region; and
- Main points of attention for European companies that are active in this specific region.
Developments in intercompany financial transactions:
We host a webinar to guide you through the developments in intercompany financial transactions. Items that will be touched upon are:
- Key aspects of the (new) OECD Guidance on intercompany financial transactions;
- Impact of the Coronavirus on intercompany financial transactions;
- Attention points for transfer pricing documentation; and
- The “IBOR” transition.
Transfer Pricing & Mandatory Disclosure:
During this webinar we discuss the transfer pricing aspects of the Mandatory Disclosure.
- What kind of arrangements have to be reported;
- The specific transfer pricing hallmarks;
- Unilateral safe harbor rules;
- Transfer of hard-to-value intangibles;
- Transfer of functions, risks and assets.
- Non-TP specific hallmarks related to transfer pricing.
Transfer pricing developments India:
This webinar outlines the developments in the Indian transfer pricing landscape. In particular, attention is paid to:
- Headquarter charges & management fees
- Transfer pricing disputes & Advance Pricing Agreements
- Transfer pricing for start-ups and new manufacturing companies
- COVID-19 & Transfer pricing
Brazilian TP/Tax and OECD:
The Brazilian transfer pricing legislation is often experienced to be quite complex and different to other countries.
During this webinar we discuss the Brazilian transfer pricing landscape, incl.
- Current stage of Brazil ascension to the OECD;
- Head office expenses allocation; and
- Snapshots of Brazilian Tax Reform.
Transfer pricing developments Germany:
Germany’s new draft law will significantly impact day-to-day transfer pricing.
During this webinar we guide you through the German transfer pricing landscape, incl.:
- The German interpretation of the arm’s length principle.
- Intercompany financing.
- Relocation of functions.
Controversy in a post-Corona era:
Tax authorities will likely assess companies’ transfer pricing policies to increase revenues.
During this webinar we will provide you with attention points on how to prepare, incl.:
- The impact of the increased transparency post-BEPS.
- Choices in strategy towards controversy: proactive vs. reactive.
- Set-up of a robust Tax Control Framework.
Doing business in the Netherlands and Transfer Pricing:
This Webinar is focused on the Taiwanese community. Topics on the agenda are:
- The investment climate of the Netherlands with a focus on the main considerations of setting-up a business in the Netherlands.
- An overview of the latest developments in the Transfer Pricing landscape.
- The several ways of alignment with the Dutch Tax Authorities.
Transfer Pricing answers for Corona times:
In this webinar we address the Transfer Pricing challenges and answers that may help you to navigate through these uncertain times:
- Possible changes in your TP policies and approaches to support your cash tax management.
- Potential changes in business models and/or supply chains and approaches for the handling of existing rulings/APAs.
What is transfer pricing?
At our QG Academy and our transfer pricing videos, the question “What is transfer pricing?” is central in the introduction of the topic. It is an area within tax law that deals with the tax consequences of pricing intercompany transactions. The main purpose is to determine the profit allocation between countries in which the multinational operates. According to international tax law, intercompany transactions must be priced at arm’s length: the parties involved in the intercompany transaction must act in the same way as third-parties would under similar circumstances.
The relevance and challenges
Transfer pricing is relevant for the core business itself. You need appropriate transfer pricing mechanisms to have a good overview of loss-making and profit-making entities. Transfer pricing should support the business, but it must also provide insights that help in making strategic decisions. Globalization has increased the relevance and complexity. Your company’s transfer pricing policy has to be in line with international guidelines such as the OECD transfer pricing guidelines as well as national guidelines. This requires a well-developed transfer pricing policy and solid documentation.
Some typical points of attention in practice are:
- Intercompany agreements
- Compensable losses and consistent loss-making
- Developments within the business
- Identifying all intercompany transactions
- Risk of double taxation
Transfer pricing overview
Quantera Global is an expert in transfer pricing. Our transfer pricing services include: governance, design & strategy, implementation, compliance, financial transactions and controversy. More information about our services? Read more about our transfer pricing services. Rather watch the transfer pricing videos? Please select a topic.