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"TPA Global's Approach on Holistic Quantitative Value Chain Analysis And The Connection To The" Unified "Approach"

Value Chain Analysis (“VCA”) has become a burning topic for discussion. It is of high importance, companies to understand how to conduct a Value chain analysis in order to support their transactions and define the value creation processes. Conducting a VCA analysis plays a vital role on supporting TP documentation, negotiation, communication to the board and other stakeholders.

We are all aware that there is a need for both qualitative and quantitative analysis, in order to identify the key allocation keys. In order to make this analysis more objective there are three (3) anchors that no to be followed: 

  • Regulatory anchor-countries regulation requirements
  • Industry anchor value drivers that have an economically significant impact on your EBIT
  • BEPS-compliant anchor BEPS criteria for a proper quantification of carve-outs and allocation to countries / legal entities

In this regard, an industry-wide analysis needs to be performed in order to enhance the robustness of the outcome. This process adds an extra layer or objectivity to quantification.

In addition to that, on 9 th of October 2019 OECD released the Unified Approach. The proposed Unified Approach under Pillar One, which is an important step forward towards an agreement among the member countries of the OECD in reaching a consensus solution for reforming the international tax framework. The determination of how the amount is allocated is still vague and unclear (formulaic approach) but it seems that OECD leads towards the holistic approach. Thus, a holistic economic view of the activities of the MNE group and further, analysis and align the operating model is of high importance.

Key Highlights

With this objective in mind, we invite you to an informative webinar where we will discuss the following:

  • Presentation of TPA Global's holistic quantitative VCA analysis
  • Explanation with examples of the Industry-wide quantitative VCA 
  • Explanation of the "Unified Appraoch" 
  • Where does the "Unified Approach" lead to? 

Speakers

Wednesday, January 22, 2020

9:00 AM - 10:00 AM Mexico, USA and Canada
12:00 AM - 1:00 PM Brazil (BRT)
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow (MSK)

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“How To Deal With Uncertain Tax Positions And The Mandatory Disclosure Under DAC-6?"

Do uncertain tax positions as disclosed in your financial accounts under IFRS or US GAAP create reportable transactions under DAC - 6 and vice-versa?

Both accounting standards and DAC - 6 are putting disclosure requirements on taxpayers for perceived "aggressive" tax arrangements, however the background and rational of these rules differ. Under DAC - 6, tax authorities for more transparency around very specifically defined (ie, Hallmarks) transactions whereas the accounting standard board wants to ensure that all (tax) risks are accounted for to avoid misleading investors and other relevant stakeholders.

Given these different goals pursued, the disclosures under each system are different and thus miss-alignment is programmed. Under DAC -6 specific transactions are targeted for disclosure to tax authorities, whereas accounting standards capture every tax related risk and require disclosure to all stakeholders.

Key Highlights

With this objective in mind, we invite you to an informative webinar where we will discuss the following:

• An overview of how the tax treatments (positions) are made under IFRIC 23 and ASC 740;
• An overview of the mandatory disclosures required to be made under DAC6; 
• Discussion on whether an uncertain tax position will lead to a DAC 6 disclosure and examples of such disclosures

Speakers

Thursday, January 30, 2020

9:00 AM - 10:00 AM Mexico, USA and Canada
12:00 AM - 1:00 PM Brazil (BRT)
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow (MSK)

Register now


 

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