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.
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If you are attending ITR (International Tax Review) Global Transfer Pricing Forum in New York on September 26th, make sure to listen in on the panel discussion on the "the industry impact of Pillar One - Amount B" with EXA AG 's Dr Frank Schoeneborn . #transferpricing
We are looking forward to ITR’s 24th annual Global Transfer Pricing Forum USA which returns to New York on Thursday September 26. The forum is Free to Attend for in-house tax professionals https://lnkd.in/enRTRutb Our speaker panel will discuss the key issues surrounding transfer pricing with a dedicated panel discussion on “the latest insights on the industry impact of Pillar One – Amount B” We will discuss to what extent does Amount B provide simplification and additional tax certainty and what are the data, process & technology implications and how do you ensure your compliance with amount B rules. Speakers include: Selena Schneider, PhD, Senior Director, Transfer Pricing, TE Connectivity Robin Hart, Principal, Charles River Associates Dr Frank Schoeneborn, Global Head of Operational TP Software Program, EXA AG #TPForumUS #Taxadvisors #Taxprofesionals #Taxautorities #transferpricing #ITRevents #InternationalTaxReview #Pillar2
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In the latest edition of Internationale Fiscale Actualiteit (4/2024), Alongsight Legal colleague Wouter Strijckers provides a thorough analysis of the new transfer pricing documentation forms – the #LocalFile, #MasterFile, and #CbC notification – that will come into effect on 1 January 2025. While these changes may seem minor at first glance, significant new information will need to be reported. For example, the mandatory inclusion of available transfer pricing documentation in the Local File is a major shift for taxpayers to consider. The Master File’s expanded requirements, especially around the value chain, financial transactions, and intangibles, also surpass OECD standards, further increasing the compliance burden. Definitely worth a read for anyone navigating the evolving TP landscape in Belgium! #Belgium #Tax #TP #TransferPricing #TaxCompliance #InternationalTax
In the latest edition of Internationale Fiscale Actualiteit (4/2024), I have commented on the new transfer pricing documentation forms (Local File, Master File and CbC notification) that will be applicable as of 1 January 2025. Although at first sight the changes might seem limited, the additional guidance to these forms clarifies that important new information will need to be included in the Belgian Local File and Master File. In the Local File, the mandatory inclusion of available TP documentation is a significant change that should be taken into account by taxpayers. The increased Master File requirements regarding among others the description of the value chain, financial transactions and intangibles will also result in an increased compliance burden for multinationals, as they go beyond the OECD requirements.
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In the latest edition of Internationale Fiscale Actualiteit (4/2024), I have commented on the new transfer pricing documentation forms (Local File, Master File and CbC notification) that will be applicable as of 1 January 2025. Although at first sight the changes might seem limited, the additional guidance to these forms clarifies that important new information will need to be included in the Belgian Local File and Master File. In the Local File, the mandatory inclusion of available TP documentation is a significant change that should be taken into account by taxpayers. The increased Master File requirements regarding among others the description of the value chain, financial transactions and intangibles will also result in an increased compliance burden for multinationals, as they go beyond the OECD requirements.
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Lexology Panoramic: Transfer Pricing 2025, edited by Amanda Pedvin Varma of Steptoe LLP, is available on Lexology: https://lnkd.in/e22kfrVr Lexology Panoramic: Transfer Pricing 2025 is a quick reference guide enabling side-by-side comparison of local insights into principal legislation; enforcement authority; role of OECD Transfer Pricing Guidelines and BEPS project; transfer pricing methods; documentation and reporting; adjustments and settlement; relief from double taxation; advance pricing agreements; special topics, such as recharacterization, comparables, secondary adjustments, non-deductible intercompany payments, anti-avoidance, location savings, branches and permanent establishments, exit charges, and temporary exemptions and reductions; and recent trends. #LexologyPanoramic
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Navigating transfer pricing compliance can be complex, but the OECD’s 9-step framework provides a clear path to ensure accuracy and global compliance. Align with global standards using the OECD’s 9-step transfer pricing approach! Transfer pricing compliance is becoming increasingly complex, and staying aligned with the OECD Transfer Pricing Guidelines has never been more critical. The 9-step approach outlined in the 2022 guidelines is a comprehensive framework for ensuring compliance and reducing audit risks. By adhering to this structured approach, organizations can minimize audit risks, demonstrate compliance, and align with evolving regulations in the global transfer pricing landscape. Designed to simplify and enhance the benchmarking process, TPbenchmark provides you with the tools to implement the OECD’s 9-step approach seamlessly. By leveraging automation, advanced comparability analysis, and real-time data, TPbenchmark empowers tax professionals to navigate the complexities of transfer pricing with precision and confidence. Ready to transform your Benchmarking process? Try TPbenchmark today and take your Transfer Pricing analysis to the next level. Start your free trial today: > https://hubs.ly/Q032BS1-0 #TaxModel #TransferPricing #tpbenchmark #tax #internationaltax #transferpricingstrategy #taxcompliance
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𝐃𝐨𝐧’𝐭 𝐦𝐢𝐬𝐬 𝐭𝐡𝐞 𝐨𝐩𝐩𝐨𝐫𝐭𝐮𝐧𝐢𝐭𝐲 𝐭𝐨 𝐨𝐩𝐭𝐢𝐦𝐢𝐳𝐞 𝐲𝐨𝐮𝐫 𝐓𝐏 𝐛𝐞𝐧𝐜𝐡𝐦𝐚𝐫𝐤𝐢𝐧𝐠 𝐩𝐫𝐨𝐜𝐞𝐬𝐬𝐞𝐬! 𝐀𝐥𝐢𝐠𝐧 𝐰𝐢𝐭𝐡 𝐠𝐥𝐨𝐛𝐚𝐥 𝐬𝐭𝐚𝐧𝐝𝐚𝐫𝐝𝐬 𝐮𝐬𝐢𝐧𝐠 𝐭𝐡𝐞 𝐎𝐄𝐂𝐃’𝐬 𝟗-𝐬𝐭𝐞𝐩 𝐓𝐫𝐚𝐧𝐬𝐟𝐞𝐫 𝐏𝐫𝐢𝐜𝐢𝐧𝐠 𝐀𝐩𝐩𝐫𝐨𝐚𝐜𝐡. Transfer Pricing compliance is becoming increasingly complex, and staying aligned with the OECD Transfer Pricing Guidelines has never been more critical. The 9-step approach outlined in the 2022 guidelines is a comprehensive framework for ensuring compliance and reducing audit risks. By adhering to this structured approach, organizations can minimize audit risks, demonstrate compliance, and align with evolving regulations in the global transfer pricing landscape. Designed to simplify and enhance the benchmarking process, TPbenchmark provides you with the tools to implement the OECD’s 9-step approach seamlessly. By leveraging automation, advanced comparability analysis, and real-time data, TPbenchmark empowers tax professionals to navigate the complexities of transfer pricing with precision and confidence. Ready to transform your Benchmarking process? Try TPbenchmark today and take your transfer pricing analysis to the next level. Start your free trial today: > https://hubs.ly/Q02Z8L6w0 #TaxModel #TransferPricing #tpbenchmark #tax #internationaltax #transferpricingstrategy #taxcompliance
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New Release – Transfer Pricing Developments Around the World 2024 🌟 This essential resource for tax professionals delves deep into global transfer pricing challenges and solutions. Authored by leading experts, Raffaele Petruzzi and Michael Lang, it provides: ✔ Analysis of OECD and EU directives ✔ Insights into BEFIT, ESG, and modern profit attribution ✔ A roadmap for navigating international tax compliance Whether you're a corporate leader, tax advisor, or policymaker, this book offers the expertise you need. Order now at clnzbooks.com with free worldwide shipping! Link: https://lnkd.in/d4gDJnDH #InternationalTax #TransferPricing #CorporateGovernance #TaxCompliance #TaxLawProfessionals #clnzbooks #clnzbookslaw
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🚨 New Release Alert! 🚨 We are pleased to unveil our new Expert Guide to Transfer Pricing Documentation -- a must-have resource for navigating the complexities of transfer pricing across multiple jurisdictions. 💼 What’s Inside? - Transfer Pricing Documentation: Understand who needs to maintain documentation, what it should include, and how it aligns with EU and OECD guidelines. - Country-by-Country Reporting (CbCR): Get insights into filing requirements, implementation status, and compliance with international standards. - Additional Requirements: Learn about local obligations and potential penalties. 🎯 How This Guide Helps You - Simplify Compliance: Grasp key documentation requirements at a glance. Facilitate Comparison: Compare transfer pricing rules across countries with ease. - Stay Informed: Keep up with the latest regulatory developments. Explore how this comprehensive guide can support your global business strategy and help you stay ahead in a dynamic regulatory environment. 👉 https://lnkd.in/e_3aymPg #CMSlaw #Tax #TransferPricing #CbCR #Compliance #TaxDocumentation CMS Tax Group
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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
🚨 New Release Alert! 🚨 We are pleased to unveil our new Expert Guide to Transfer Pricing Documentation -- a must-have resource for navigating the complexities of transfer pricing across multiple jurisdictions. 💼 What’s Inside? - Transfer Pricing Documentation: Understand who needs to maintain documentation, what it should include, and how it aligns with EU and OECD guidelines. - Country-by-Country Reporting (CbCR): Get insights into filing requirements, implementation status, and compliance with international standards. - Additional Requirements: Learn about local obligations and potential penalties. 🎯 How This Guide Helps You - Simplify Compliance: Grasp key documentation requirements at a glance. Facilitate Comparison: Compare transfer pricing rules across countries with ease. - Stay Informed: Keep up with the latest regulatory developments. Explore how this comprehensive guide can support your global business strategy and help you stay ahead in a dynamic regulatory environment. 👉 https://lnkd.in/e_3aymPg #CMSlaw #Tax #TransferPricing #CbCR #Compliance #TaxDocumentation CMS Tax Group
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𝐏𝐢𝐥𝐥𝐚𝐫 𝐓𝐰𝐨 𝐢𝐧 𝐁𝐞𝐥𝐠𝐢𝐮𝐦: 𝐑𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐫𝐞𝐪𝐮𝐢𝐫𝐞𝐬 𝐢𝐦𝐦𝐞𝐝𝐢𝐚𝐭𝐞 𝐚𝐜𝐭𝐢𝐨𝐧! Groups with Belgian entities that fall under the Pillar Two rules must register at the Crossroads Bank for Enterprises and therefore need to take immediate action. Those already within scope must file the notification form by July 13, 2024. Other groups must submit the form within 30 days after the start of the Fiscal Year for which the group enters into the scope of the Pillar Two rules. Don't delay—ensure your compliance today! Read the latest article of Linda Brosens, Nicolas Lippens and Aldo Engels for detailed instructions on registration and the required information. 🔗Read more on our website: https://lawand.tax/4bCgaZ4 #tax #taxlaw #pillar2 #belgium
Pillar Two in Belgium: Registration requires immediate action!
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Senior Associate at Lubbers, Boer & Douma | PhD Candidate
3moWillem-Jan Van Veen