KPMG Webinar: Current transfer pricing challenges. What steps should be taken?

The COVID 19 crisis is likely to have significant implications for many companies’ transfer pricing policies. Disruption, changes to commercial flows, new ways of doing business, and potentially lower profits will all affect what companies’ 2020 transfer pricing files will look like. This presents challenges from a compliance perspective, especially as tax authorities throughout the world are now particularly keen to protect revenue.

So companies should consider whether they need to adjust their transfer prices. If changes have occurred to profitability and some subsidiaries are now making losses, they should prepare careful documentation to demonstrate this. Determining economic losses may require sophisticated economic modeling and income-based analysis. Care should be paid to benchmark studies, as these are one year behind and may not accurately reflect the arm’s length nature of transactions in 2020. Some long term analysis will be needed, to consider how transfer pricing positions might evolve over the next few years.

Agenda

• Transfer pricing challenges at world level;
• Reorganizations and changes of business models, which lead to changes in transfer pricing policies;
• Amendments of the contractual relationships with both third parties and companies from the group, which may trigger changes in functional profile;
• Inherent costs of the COVID 19 crisis and the need to document these costs;
• Financing, including cash pooling arrangements. The need to revise finance and payment structures;
• Already obtained or in progress Advance Pricing Agreements;
• Anticipating tax / transfer pricing audits on transfer pricing;
• Q&A
  
  

The webinar will be hosted by:

Teodora Alecu, Director, Transfer Pricing Services, KPMG in Romania
Cristina Vasilescu, Director, Transfer Pricing Services, KPMG in Romania
Alexandra Ion, Senior Manager, Transfer Pricing Services, KPMG in Romania
Anca Tudor, Manager, Transfer Pricing Services, KPMG in Romania
Ioana Urse, Associate Manager, Transfer Pricing Services, KPMG in Romania