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TRANSFER PRICING FOR BEPS
One System. One Story. Global Control.Transfer pricing documentation has undergone a seismic shift with the introduction of the OECD’s Base Erosion Profit Shifting initiative. In a pre-BEPS world, multinational enterprises (MNEs) could focus on each individual country’s documentation requirements and deal with scrutiny at the local level. As long as documentation was in compliance with local transfer pricing rules, organizations were relatively free from inquiries from foreign tax authorities.
With the advent of the BEPS Action Plan, multinational enterprises of all sizes will see an exponential increase in the risks involved with maintaining the status quo. Implementation is expected by OECD member countries and many other countries between 2016 and 2017. Once implemented, tax authorities will gain worldwide visibility into a company’s global operations. An inconsistent transfer pricing documentation story presented to active jurisdictions may lead to scrutiny that extends beyond the realm of tax. ONESOURCE Transfer Pricing is here to help your organization tackle complex regulations and achieve success on a global scale.
A NEW REPORTING STANDARDIn BEPS Action Item 13, the OECD rewrote Chapter V of the OECD Transfer Pricing Guidelines, previously considered to be the standard guidance for transfer pricing documentation which many tax authorities specifically reference in the development of their local rules. In the revised Chapter V, the OECD outlines a three-tiered approach to transfer pricing documentation in order to standardize processes and to facilitate communication between local tax authorities and MNEs.
“In order to achieve the objectives described [above] countries should adopt a standardized approach to transfer pricing documentation” -Chapter V, OECD Guidelines, September 2014
ONESOURCE TRANSFER PRICING for BEPS
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Transfer_Pricing_BEPs_SL_012015
Under BEPS, MNEs will prepare a global master file with standardized information for the MNE, a local file for material transactions, as well as a country-by-country report. This will provide tax authorities with an unprecedented view into company’s tax structure and value chain. For tax professionals accustomed to in-country reporting, several questions may arise:• Do we have the right amount of information? • What is the added time and cost of compliance? • How can we ensure consistency in our story,
processes, and how policies are enforced? • What is my story globally?
ONE STORY
Transfer pricing in a BEPS world requires multinationals to know, align, and tell their story with consistency. Whether you outsource transfer pricing, perform it in-house, or prefer a combined approach, ONESOURCE Transfer Pricing can help you achieve a level of transparency with a reporting and process control system across all areas. With one place to review all documentation messages and a team of transfer pricing experts equipped with the know-how to assist MNEs of all sizes worldwide, you will be able to align your story along with tax base positions and policies across all of the countries you operate.
GLOBAL CONTROLIn a recent survey, 57% of large companies identified a lack of process or technology as the leading source of operational tax risk. The BEPS initiative highlights the importance of global control in mitigating these risks and presents an opportunity for MNEs to gain additional system-visibility into the impact of changes
made to policies on a global scale. Upgrading your in-house information systems with the scalability to address ever-increasing amounts of data will give you the chance to own your process and align your global story with greater control. Availability of information means you can analyze, consolidate, and report with whichever level of granularity and transparency is necessary. ONESOURCE Transfer Pricing can help you establish your policy, enforce it across the organization, maintain an audit trail, and become a world class international tax department.
ONE SYSTEMSome organizations seem prepared for BEPS at a local level. However on a global scale, there may be outsourced serviced partners, a lack of centralized documentation and global story, or a limited ability to report by entity or by segment. ONESOURCE Transfer Pricing enables you to leverage a global, transfer pricing-specific control system that seamlessly weaves together a combination of software, services, data, and expertise in one location. With one system, you can focus on how to make your transfer pricing process more efficient. For companies that have not yet formed a strategy, having one system will provide the structure to begin transforming your process.
ONESOURCE Transfer Pricing for BEPS empowers professionals like you to analyze, consolidate, and report to tax authorities at a world class level of consistency and transparency. With technology, you can help manage project workflows, transform transfer pricing data, research worldwide third party data, and analyze intercompany transactions on a global scale. You can then use this knowledge to create robust reports that meets OECD and country-specific requirements.
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Through software, service, data and expertise, only Thomson Reuters ONESOURCE Transfer Pricing brings together everything you need to know, align and tell one story at every level of your business — with global transparency, cross-country consistency and in-country certainty.
Tax professionals should be able to manage inter-company transactions with systematic discipline, worldwide.
