Please join us for the first program in our Transfer Pricing: The New Frontier webinar series.

BEPS has emboldened global tax authorities by imposing unprecedented transparency requirements on multinational organizations. For example, the 2015 BEPS Action 13 has reinforced substantive transfer pricing rules, significantly altering the transfer pricing landscape. Codified by the 2017 OECD Transfer Pricing Guidelines, which have been adopted in many European jurisdictions and partially implemented in the United States, the new requirements are forcing taxpayers to rethink their approach to transfer pricing documentation in a growing number of jurisdictions, although the pace and scope of the change vary from country to country. 

Our panel will identify issues to consider when preparing your transfer pricing documentation, including the Master File, the Local File and the Country-by-Country Report (IRS Form 8975). Considerations include the appropriate level of detail to include in the Master and Local Files, “disclosure” concerns, consistency across jurisdictions, and proper identification and documentation of key value drivers across the organization. We’ll also discuss why it’s vital to align legal framework and contractual allocation of risks and functions with economic substance and the parties’ actual conduct.

CLE credit is pending.

For additional information or to register, please contact Shilpa Patel at spatel@mayerbrown.com or +1 312 701 8487.

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