Brian Foley’s Post

📔 [NEW MODEL MANUAL FOR CRS COMPLIANCE AUDITS] Having developed a Model Administrative Compliance Strategy to assist Global Forum members in developing, improving and implementing their own administrative compliance strategy to ensure the effectiveness of the Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI), the Global Forum Secretariat launched today a 𝗠𝗼𝗱𝗲𝗹 𝗠𝗮𝗻𝘂𝗮𝗹 𝗳𝗼𝗿 𝗖𝗥𝗦 𝗖𝗼𝗺𝗽𝗹𝗶𝗮𝗻𝗰𝗲 𝗔𝘂𝗱𝗶𝘁𝘀, that jurisdictions can reference to when developing, improving or implementing their own procedures and methodologies for conducting CRS compliance audits. The Manual was launched in a virtual event attended by 433 delegates from 105 jurisdictions. It is 𝗮𝘃𝗮𝗶𝗹𝗮𝗯𝗹𝗲 𝗼𝗻 𝗱𝗲𝗺𝗮𝗻𝗱 𝘁𝗼 𝗮𝗹𝗹 𝗶𝗻𝘁𝗲𝗿𝗲𝘀𝘁𝗲𝗱 𝗷𝘂𝗿𝗶𝘀𝗱𝗶𝗰𝘁𝗶𝗼𝗻𝘀 𝗶𝗻 𝗘𝗻𝗴𝗹𝗶𝘀𝗵, 𝗙𝗿𝗲𝗻𝗰𝗵 𝗮𝗻𝗱 𝗦𝗽𝗮𝗻𝗶𝘀𝗵. Find out more 👉 https://lnkd.in/eDMnj4nK Browse all our capacity-building tools available to tax authorities upon request 👉 https://lnkd.in/e_xsZPTi #GlobalForum #taxtransparency #automaticexchange #CRS #AEOI #compliance #capacitybuilding #experiencesharing Hakim Hamadi Miguel Morelos Colin Bin YAN Raynald Vial Aurore Arcambal Radhanath Housden

Back in January of this year, HMRC released its updated operational guidance on the role of risk in a transfer pricing analysis. The guidance seeks to explain HMRCs view on the interpretation of the six-step process for analysing risk in Chapter I, OECD TPG. It provides extensive insight into HMRC’s views on the analysis of economically significant risks and their management, along with how to assess the contributions to risk control made by members of a MNE group and the arm’s length reward for these contributions. If you would like to read more, we previously prepared a tax alert on HMRC’s guidance (attached). This is a contentious area and, as the guidance itself notes, some commentators firmly disagree with HMRC’s perspective. Taxpayers should expect this to be a continuing area of focus in any discussions with HMRC. It is therefore important to proactively consider your positions, be that in the context of a developing and implementing new policies, preparing annual TP documentation, preparing for a PDCF, managing a tax enquiry, and/or engaging in a mutual agreement procedure or an advance pricing agreement. Given the significance of this issue, we have, based on our extensive experience working with clients on this issue to date, developed an “ESR assessment” approach - being a two phased (feasibility / health check, and a detailed analysis phase) to assess the robustness of TP policies, documentation, evidence of risk control activities and governance processes in light of HMRC’s guidance and the guidance in the OECD TPG. If you would like to have a further discussion about how EY can assist you, please reach out to your EY UK TP contact, or drop me a message and I can connect you with one of our team! #tax #transferpricing #Ey #taxcontroversy #oecdtpg #hmrc #uktp

It certainly feels like HMRC will be sharpening their pencil around the role of risk in transfer pricing. Although HMRC notes that analysis of risk alone is not the only consideration for accurately delineating an actual transaction, we are expecting to see greater challenges around adequete evidence of risk control contributions, and consideration of contractual allocation of risk with the capacity to control and financially assume the up/downside outcomes of economically significant risks. Whilst these concepts are not new and stem from Chapter II of the OECD TPG, this guidance suggests that HMRC will be expecting a more detailed consideration of risk as the new UK TP doc reporting requirements are rolled out this year.

Read All About It! New Blog Post Published Today! 🗞️🌟 https://lnkd.in/g6SJPGBP #TaxCompliance #IncomeTax #GSTFiling #TDS #EPF #ESI #ROCCompliance #BusinessCompliance #August2024 #TaxTracker #Apnokaca #eitrfiling #myitronline

Our #GCC #ITX News Roundup for Q2 2024 is now live. Read about the latest updates covering #VAT, #Excisetax, #Customs & #Trade, #RETT, #einvoicing and more. Key topics in this edition include the approval of the duty-free markets requirements, acceptance of ATA Carnets and the extension of #amnesty in the #KSA.In addition, we covered PwC’s active participation in a variety of events across the region. Get in touch for further information or if you would like to discuss how these changes impact your business. https://lnkd.in/dCqURJe2 PwC Middle East #tax #customs

🚨 Attention Business Owners & Tax Pros: Don’t Miss This Critical Webinar on Reporting Beneficial Ownership Information (BOI) 🚨 The IRS is hosting a free, one-hour webinar on Nov. 19, 2024, at 2 p.m. ET to help businesses understand and comply with the Corporate Transparency Act (CTA). This new requirement mandates many companies formed before Jan. 1, 2024, to e-file their Beneficial Ownership Information (BOI) to FinCEN by Jan. 1, 2025. Key Topics: - CTA overview & BOI reporting requirements - Compliance resources & guidance - Penalties for non-compliance - Live Q&A with FinCEN experts This session is open to all, especially tax professionals.   No CE credits but certificates of completion available.   Closed captioning will be provided. 🗓️ Date: Nov. 19, 2024, 2 p.m. ET   📍 Register: Visit the Internal Revenue Service webinar website  Fore more such updates from #IRS, follow DiligenceOS Global Pvt. Ltd. #CorporateTransparency #CTA #FinCEN #IRSWebinar #TaxCompliance #Webinar

⚠️ First Pillar Two legislation in the GCC ⚠️

The International Compliance Assurance Programme (ICAP) is a dispute prevention alternative to advance pricing agreements that may become more popular given complexities around Amount B and Pillar 2. See our recent alert on the updated ICAP FAQs and information on participating tax administrations publications. #transferpricing #internationaltax #ICAP #OECD #EY https://lnkd.in/eYViawNT

Eager to learn more about operational transfer pricing or the key takeaways from EY's 2024 International Tax and TP survey? Register now to our upcoming (complimentary) technical TP meetings, in both Amsterdam and Rotterdam here: https://lnkd.in/eW7uYiVE Concerns about double taxation resulting from global tax reforms are fundamentally transforming the way businesses think about their transfer pricing certainty and their operational TP needs. The availability of robust and auditable tax and TP data is in this respect an absolute prerequisite for ensuring certainty in an ever-increasingly complex tax realm. While the need to structured, standardized and harmonized tax data is relevant for operational TP purposes (e.g., financial segmentation, TP adjustments, Amount B), it is equally relevant for other tax areas (e.g., Pillar 2, public CbCR, indirect taxes) and non-tax areas (e.g., sustainability-linked / financial reporting). 📅 Date: 19 and 25 March 2024 ⏰ Time: 10:00 – 12:00 📍 Location: EY Amsterdam (19 March) & EY Rotterdam (25 March) 🔍 During these events, you'll have the opportunity to partake in active dialogues: jump into lively discussions with EY's OTP experts and peers on operational transfer pricing. 💬 Link with industry contemporaries: Engage with your direct cross-sector peers on practical experiences and solutions pertaining to (the execution of) OTP. This event is designed for both tax and TP in-house professionals, experienced or just starting out, as the knowledge shared during these sessions may benefit all. If you have any questions, do not hesitate to contact me, your usual EY contact or any of Tim Meijer, Sebastiaan Kuijper, Gabor Baranyai, Krzysztof Łukosz, Bo Wingerter, Jeroen Geevers, Lucy Satiyan, Sophie Slagter or Wouter Schelfaut #transferpricing #TP #OperationalTP #OTP #OTPsolutions

The (FTA) has outlined five categories of transfer pricing documentation that should be prepared for each tax year. 1. Transfer Pricing Disclosure Form (TPDF): Similar to a declaration, covering transaction details with related parties. Must be submitted with the corporate tax return within 9 months from the financial year-end. 2. Master File: Provides a high-level overview of a multinational group’s global operations and transfer pricing policies. 3. Local File: Contains detailed information on the management and operations of the local entity, along with comparability and functional analysis. 4. Country-by-country report (CbCR): Applicable to multinational groups with consolidated annual revenue of Dh3.15 billion or more. 5. Additional supporting information: Empowers FTA to request for further documentation to determine compliance with arm’s length principle. Businesses should fortify their reporting and documentation process to minimize anxiety in transitioning to the new tax regime. Chat with us to learn more at, https://lnkd.in/dyaMYN6K #TaxCompliance #UAECorporateTax #RFZConsulting #RFZAccounting #TaxUpdates