Anita Lakhotia’s Post

Interesting to read in a blog post by Thomas Hug, Daniel Stutzmann Hausmann and Manuel Angehrn of Deloitte Switzerland (blog post here: https://lnkd.in/epzJ8CKJ) and subsequent LinkedIn discussion that the Swiss government is not yet implementing the Undertaxed Payment Rule (UTPR) of Pillar Two as per 1 January 2025. To quote Thomas' response to my question whether there is a relationship with the US (prior to the US elections questions were raised in Dutch parliament (Tweede Kamer der Staten-Generaal) on the question whether there were any concerns about the proposed Defending American Jobs and Investment Act and the Unfair Tax Prevention Act) or whether there are more fundamental concerns on the side of the Swiss: "Official statement by government: legal uncertainty and economic risks are disproportionate to the additional tax revenues" The Netherlands is (save for the exceptions contained within the GloBE Model Rules as implemented in the EU through the Pillar Two Directive) set to have the UTPR enter into effect from 2025, in line with the EU Pillar Two Directive. Wonder whether parliaments in other EU Member States and/or the European Commission are monitoring these developments and are perhaps reconsidering the entry into effect of the UTPR.

A good start to anything difficult is getting the basics right. Getting the reporting and planning right across the entire organisation, gives control over the data needed to answer the difficult questions.

Get the right tools, processes and models in place to handle transfer pricing in the best way possible. Concerns about the predictability of Pillar Two calculations amongst executives and TP professionals are centred around data, in particular standard transfer pricing data - leading to EP’s 2024 survey to state in no uncertain terms that the operational needs and data processes must compel corporations to attempt to standardise their internal data to manage the groundswell of tax authority controversy-related requests and Pillar Two calculations. Specifically, they clarify: “Standardised data will help businesses address workload demands and effectively manage current and anticipated tax controversy. More control over their data will also help businesses manage increasing demands for public transparency about their tax payments globally.” If you need support standardising cross-country and cross-department data processes, book in a call with our financial consultants. info@insightmodels.co.uk And for more on transfer pricing and Pillar Two, explore our recent article: https://lnkd.in/entkUtnM #PillarTwo #MNE #FinanceTeams #FinancialPlanning #MultinationalEnterprise

Did you miss our 2024 Virtual Client Event last week? While the event may be over, we're here to give you our top 3 takeaways from the session: 1. There’s a significant increase in demand for tax and transfer pricing technology 2. In-house tax and transfer pricing specialists see the need for technology because of the significant increase in their tasks. 3. Public CbCR, Pillar 1 (Amount B) and Pillar 2 are the main talking points in transfer pricing at the moment. Want to know more? Feel free to reach out to David Zářecký, Lennart van den Kommer, Allard Posthuma, or any of our other amazing TP specialists to assist you with your transfer pricing documentation needs!

We had a full house at our #GlobalMinimumTax (GMT) webinar last week, open to clients and colleagues across the APAC region. Such a hot topic! 🔥 For those who missed it, you can still catch up by checking out the webinar recording. With the #OECD’s Pillar Two tax framework gaining significant traction, it's crucial for multinational companies to stay informed and prepared for the implementation of GMT rules. As always, feel free to reach out to our team for any #transferpricing advisory needs! https://lnkd.in/dj4HeK6M #GlobalMinimumTax #TransferPricing #OECD #PillarTwo #InternationalTax #Webinar #TaxAdvisory #APAC #GMT #TaxCompliance

🚀 Harnessing Technology for BEPS Pillar Two: A Game-Changer for International Tax Compliance 💡 While it may not always steal the spotlight, navigating the intricacies of Pillar Two compliance can sometimes feel like traversing a labyrinth. That's where technology solutions come in as our trusty guide. By leveraging innovative tech tools, we can simplify complex processes, enhance transparency, and stay ahead of regulatory changes. Picture this: automated risk assessment, real-time data analytics, and streamlined reporting—all at your fingertips. These tech-driven solutions empower tax professionals to tackle Pillar Two challenges with precision and efficiency. So, let's embrace the power of technology and transform P2 compliance from a daunting task into a strategic advantage. Together, we can navigate the ever-changing landscape of international tax regulations and drive sustainable growth for businesses worldwide. 💼🌐 #BEPS #TaxCompliance #TechnologyInnovation #ARKKSolutions

The #OECD Guidelines (2017 Chapter V, Annex II) prescribe that transfer pricing local files should include the key competitors of the local entity. Why? The rationale for having this type of information is for the tax administrations to: ✔️Understand the key players in the industry, the value chain, the supply chain, and the typical margins, ✔️Understanding the intensity of competition, i.e., a highly competitive field, may justify lower margins and vice versa, ✔️Compare the competitors' available data (i.e., financials) with the relevant taxpayer, i.e., to understand and make a high-over comparison of the operating margins of the taxpayer’s peers. Do you need help preparing your transfer pricing documentation? Our tax and IT professionals are always available to help. Visit https://hubs.ly/Q02GVwjr0 #tpd #transferpricing #OECD #OECDtax #financialtransactions #MNEs #beps #taxtechnology #taxtech #crossbordertransactions #taxadministration

The CMS Expert Guide to Transfer Pricing Documentation is an invaluable resource for businesses navigating the complexities of transfer pricing across multiple jurisdictions. It offers detailed insights into documentation requirements, Country-by-Country Reporting (CbCR), and local obligations, all aligned with EU and OECD guidelines. This guide simplifies compliance, facilitates cross-country comparisons, and keeps you informed about the latest regulatory developments. Explore how it can support your global business strategy and help you stay ahead in a dynamic regulatory environment. #CMSlaw #Tax #TransferPricing #CbCR #Compliance #TaxDocumentation

Over 35 countries adopted Pillar Two legislation effective January 1, 2024. Requiring over 200 separate new data points per legal entity, are you ready for the Pillar Two's impact on your financial reporting processes?

I’m delighted to be speaking at the ITR Global Transfer Pricing Forum, which takes place in Amsterdam on 11 & 12 September. I hope you can join me at the Forum for some cutting-edge taxation discussions and presentations. I will be sharing my experiences on a panel discussion – come join the conversation! You can register to attend here https://bit.ly/TPEU24SPK #GlobalTPForum #ITRevents #InternationalTaxReview #TaxAdvisors #TaxProfessionals #TaxAuthorities #TransferPricing