KPMG report: Year-end tax discussion ideas for international tax and transfer pricing

Conversations between taxpayers and their tax advisors for year-end planning purposes

Year-end tax discussion ideas

This year has not been normal—not even a new normal—and it is already apparent that 2023 won’t be either. The Ukraine-Russia conflict, continued supply chain disruptions, and concern over an impending recession have resulted in economic disruptions that will continue in the coming year. Though there have been delays to the OECD’s BEPS 2.0 project, it is expected that Pillar Two (minimum tax) will be implemented in 2023, coming into effect in countries such as France, Germany, Italy, Spain, and United Kingdom in 2024. By contrast, the future of Pillar One (revised profit allocation rules) remains less certain.

All these developments bear on international tax and transfer pricing and would factor into year-end discussions. At the same time, existing planning opportunities often play an important role in year-end talks.

Conversations between taxpayers and their tax advisors for year-end planning purposes could include discussions about the following key international tax and transfer pricing issues:

  • Recessionary concerns
  • Foreign-derived intangible income (FDII) planning
  • Supply chain disruptions
  • 2022 deduction for worthlessness from Russian operation exits
  • Debt-related Russian issues
  • Planning due to rising interest rates
  • Reevaluating transfer prices in light of a recent U.S. court case
  • Foreign tax redeterminations based on transfer pricing settlements
  • Impending changes in and planning opportunities in Brazil
  • Monitoring BEPS 2.0
  • Issues arising from year-end adjustments
  • Key upcoming changes in the transfer pricing compliance landscape

Read a November 2022 report [PDF 229 KB] prepared by KPMG LLP: What’s News in Tax: International Tax and Transfer Pricing Ideas for Year-End Discussions


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