Transfer pricing. Are you ready?
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- Russell Francis
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1 Transfer pricing Are you ready?
2 Transfer pricing is a major challenge You are A multinational A foreign group with operations in France An SME with plans for international expansion Transfer pricing is experiencing a transformation, driven by the OECD and the BEPS* action plan The international tax rules governing transfer pricing are undergoing changes that are nothing short of a revolution changes which have a direct local impact on businesses. Documentary requirements for multinationals are being tightened Mandatory upstream preparation of transfer pricing documentation Filing of so-called simplified declarations Introduction of specific sanctions Greater transparency through country-by-country reporting 129 % Rise in transfer pricing adjustments in France from 2010 to Adjustments in 2011 totaled 3.2 billion (Source: Ministry of the Economy). Why choose EY Société d Avocats? A single point of contact to provide an integrated approach tailored to your operational and financial needs. Confidentiality is assured Across-the-board expertise spanning law and taxation, economics, finance and accounting Independent advice guaranteed from a regulated profession subject to a strict code of ethics Ready access to a network of lawyers and experts specializing in transfer pricing Support from an international network of legal and tax experts, to offer you solutions aligned with your objectives in an international context *BEPS : «Base Erosion and Profit Shifting»
3 Our expertise at your service We employ methodologies that anticipate your expectations, ensuring smooth and efficient processes. We strive to find the right balance between technical proficiency and pragmatism, as well as to share experience and transfer skills. A dedicated team Comprising over 50 transfer pricing specialists (lawyers and economists) Doc um en t ce & Défense n A n a l ys e é c o Transfer pricing A ue ss iq i st om an offices in Paris, Lille, Lyon, Nantes and Strasbourg Dia gn d o pr e l s ix With a nationwide presence through n io at ition éfin d e et tiqu rt tic poli ansfe a tr de Evaluation... offering you solutions tailored to your industry And in particular: Automotive Financial services Power and utilities FMCG Engineering and construction Media and entertainment Oil and gas Chemicals and pharmaceuticals Industrial products Technology Telecommunications Transports
4 Our know-how Evaluation and economic analysis Valuation for tax purposes of securities, liabilities and/or tangible and intangible assets in the context of intra-group restructuring Identification and analysis of Options Realistically Available ( ORA ) in the context of intra-group transactions Economic analysis: benchmarking, profit split analysis, determination of interest rates and guarantee fees / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / Scoping and defining transfer pricing policies Value chain and business process analysis Identification of risks and opportunities Setting transfer pricing policies in alignment with operational needs / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / Documentation Preparing group/company transfer pricing documentation in compliance with current regulations in coordination with EY s global organization Creation of master files, local files and country-by-country reports (CbCRs) / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / Disputes and international proceedings Assistance with dealing with tax authorities during on-site audits and/or during the pre-trial (responses to proposed adjustments, administrative appeals) and trial phases Assistance with tax-related police raids (French Code of Fiscal Procedures, Article L.16 B) Assistance during mutual agreement procedures aimed at eliminating double taxation caused by transfer pricing adjustments Negotiating Advance Pricing Arrangements
5 The strength of the EY global organization 728 offices countries Americas EMEIA Japan Asia-Pacific Awards for EY Société d Avocats Transfer Pricing Firm of the Year 2014 & 2015 International Tax Review «««««Rating for transfer pricing, 2015 Option Finance
6 Ernst & Young Société d Avocats EY Société d Avocats is one of the French leading firms in tax and law. Through our membership in a global organization, we put our expertise to serve a sustainable and responsible performance. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our clients, for our and for our communities. Ernst & Young Société d Avocats Registered with the Hauts-de-Seine Bar (France) Member of Ernst & Young Global limited EY refers to the global organization and may refer to one or more of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com Ernst & Young Société d Avocats. All rights reserved Studio EY France SG621 SCORE France N In line with EY s commitment to minimize its impact on the environment, this document has been printed on paper with a high recycled content. ey-avocats.com Your contacts Olivier Marichal Attorney-at Law, Partner EY Société d Avocats Tel.: olivier.marichal@ey-avocats.com Patrice Jan Attorney-at Law, Partner EY Société d Avocats Tel.: patrice.jan@ey-avocats.com Franck Berger Attorney-at Law, Partner EY Société d Avocats Tel.: franck.berger@ey-avocats.com Jan Martens Partner, EY Tel.: jan.martens@fr.ey.com
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