Now that the OECD has completed the bulk of its work on Base Erosion BakerMcKenzie Logoand Profit Shifting (BEPS), and nations are changing their rules in response, multinational companies will find themselves operating in a new tax landscape – one that demands more transparency than ever before about where global companies are earning profits and paying taxes.

To complicate matters, nations will not all implement the OECD’s final work in the same way. China, for example, has developed a “value creation” approach that radically departs from the established use of one-sided transfer pricing methods, such as TNMM. Multinationals are caught in the middle as they react to various nations’ interpretations, and in some cases, will need to appeal to multiple authorities to resolve their disputes.

While the BEPS project has arguably settled the issue of tax avoidance, it has created many new challenges for businesses in their day-to-day compliance and, ultimately, in their forward-looking tax planning. Documentation now will involve much more than preparing a transfer pricing study. Established supply chain structures may need to be unwound. And, more and more complex disputes will arise “post-BEPS.” Sessions at the Global Transfer Pricing Conference: Paris covered how to negotiate these issues and many more.

Featuring government officials, policy makers and leading industry experts and advisors, think and code and Baker & McKenzie’s Global Transfer Pricing Conference: Paris represented the most current and essential thought leadership in the area of transfer pricing and has become the go-to destination for multinational companies.


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