Exploring Transfer Pricing: Recent Episodes
KPMG LLP (U.S.)
In the Exploring Transfer Pricing podcast series, brought to you by KPMG TaxRadio, a KPMG manager asks senior transfer pricing professionals the questions on her mind. After listening you'll have a clearer roadmap to traverse the transfer pricing landscape, whether you're a seasoned international tax professional, an inquisitive economist, or simply a curious explorer.
While on your next shopping spree, pick up some knowledge regarding retail and consumer goods transfer pricing.
With back-to-school and seasonal shopping in full swing, we set out to explore the nuances of transfer pricing within the retail and consumer goods industry. Over the last 20 years, and more specifically in response to the COVID-19 Pandemic, the retail industry has had to evolve. This shift has resulted in the revaluation of transfer pricing for many retailers in a myriad of ways, such as reconsidering the source of value in a company's supply chain, changes in consumer purchasing habits, and the datafication of consumers.
Our host Brittany Hardin Tanguay is joined by Diane Shkodina (Managing Director, Tax - Transfer Pricing) and Nick Stavrakis (Managing Director, Tax - Transfer Pricing) to discuss the challenges transfer pricing practitioners are facing with developing an arm's-length transfer pricing range for North American retail distribution companies (and beyond).
Contacts: Diana Shkodina, Nick Stavrakis, Brittany Hardin Tanguay
Going Dutch on testing financial transactions!
In this episode we explore the Chapter 10 OECD Guidelines involving financial transactions with our KPMG Netherlands colleagues. The Netherlands has long been known as a financial services transaction hub and integral for multinational enterprises' treasury functions - why has this historically been the case? What are some of the major transfer pricing issues involving these Dutch financial entities? How does the Dutch Tax Authority reconcile the OECD Guidelines vs. Dutch Tax Laws? What role does risk play in determining the type of financial entity? If you are interested in financial services hubs, OECD Guidelines, and beautiful fields of never-ending tulips, strap on your clogs!
If Amount B is supposed to simplify transfer pricing, why does it seem so complicated? Listen as we break it down.
In this episode we explore the major announcement regarding Amount B released this week by the OECD with our KPMG knowledge leader from London. On Monday July 17, we got the latest update from the OECD on its efforts to simplify transfer pricing through Amount B, part of its BEPS 2.0 initiative to address the tax challenges of digitalization. What will this mean for multi-nationals cross-border transaction, transfer pricing policy, and future transfer pricing planning? Will Amount B actually apply to digital businesses? With all of the news regarding Amount B, we will break down the announcement and address some of the potential implications.
Your transfer pricing is in good hands, because we've seen a situation or two.
The insurance industry and its representatives exist to make people's bad days less bad. Insurance provides protection for what matters most, but how do you transfer price for managing risk? If you're unsure how reinsurance works for cross-border intercompany transactions, we've got you covered!
As part of our Industry Series, Exploring Transfer Pricing tours different industries with specialists to discuss some of what makes their industry of focus unique, and how that might impact the transfer pricing.
Why can’t all my profit just go to an offshore haven? KPMG explains Asset Management transfer pricing in a post-BEPS world.
Investment committees, sub-advisors and referral fees - Oh My! How should asset management tax practices battle the nuances of splitting highly lucrative asset management returns across their global footprints? In an industry which faces commercial pressure, non-tax regulators, and a minefield of BEPS exclusions, navigating the specific intercompany relationships within asset management may seem daunting. Tax authorities are taking very different approaches to the asset management industry, and conquering the compliance and planning opportunities has never been more timely.
As part of our Industry Series, Exploring Transfer Pricing tours different industries with specialists to discuss some of what makes their industry of focus unique, and how that might impact the transfer pricing.
Perform a check-up on your company's financial health before stressing it with debt.We've established that everybody borrows, meaning that multinational enterprises in every industry are likely to engage in some level of intercompany financing. But how is it actually done? What parts of the business need to work together, and what considerations often get overlooked when setting interest rates on these loans between related parties? Join us to learn more, and to appreciate some of the nuances that must be reflected in each transfer pricing analysis.Contacts:
Intercompany financing is not unique to any single industry or structure. Everybody borrows. Intercompany loans are issued in every multinational company, regardless of industry. Listen in to learn why some subsidiaries can be viewed as the black sheep of the family, while others as the next in line to run the business. And what does this have to do with the interest rates they are charged?