Understanding the global transfer pricing landscap − 2018

International taxation is undergoing the biggest shake-up for a generation. The already complex world of transfer pricing is at the front and centre of these disruptive changes, both in the rules that govern it and in the heightened scrutiny it now faces.

The chief driver of change is the global roll-out of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan. More than a hundred countries have pledged to implement at least some of the Action Plan elements.

Demonstrating substance

As part of the global tax reforms, your business needs to demonstrate that transfer pricing reflects the economic substance of value creation and exchange. Substance can appear quite straightforward in areas such as manufacturing, where it’s obvious that a factory or warehouse exists.

However, what we refer to here are the ‘significant people functions’ – where are the people controlling the important risks in the business, such as new product development, or procurement. Where substance gets even more complex, and makes transfer pricing all the more complicated, is in areas such as the creation and development of intellectual property and other intangible assets.

Key questions include: does transfer pricing within your organisation reflect the substance of where and how value is created and exchanged?

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Your business has got the wind in its sails and now you’re wondering what the next step in your growth should be. What path should you take to move in the right direction?

If you’re thinking about an acquisition, want to develop markets or are looking for a partner, ask the right questions before taking action. Emilio B. Imbriglio, Raymond Chabot Grant Thornton President and CEO, shares his expertise.


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Are your US sales effected? Your Sales and Use Tax compliance obligations may be greatly impacted by a Supreme Court ruling on the horizon.

Online Tax Strategies−June 2018

We are eagerly awaiting a ruling that may reshape Sales and Use Tax compliance for Canadian businesses selling into the United States.

The present state of affairs

Presently, states cannot force a business to register for nor collect sales and use tax if the business has no physical presence in the state (for example: a place of business, inventory, equipment, sales staff, independent agents, contractors, technicians). States may provide for a minimum threshold of sales for registering; however, they may not force a business to register based solely on a business’ volume of sales if they do not have any physical presence.

These precedents were established long before the prominence of internet sales, when the closest equivalent was catalogue sales (see National Bellas Hess v. Department of Revenue, 386 U.S. 753 (1967), Quill Corp. v. North Dakota, 504 U.S. 298 (1992))

However, recently states have been frustrated with the loss of tax revenue and have been challenging these precedents on the basis that they are outdated and were formulated at a time that does not square adequately with today’s economic reality.

In South Dakota v. Wayfair, inc., the Supreme Court of the United States will be in a position to change the rules, to allow states to require businesses to register based solely on the volume of sales.

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Adviser alert – May 2018

The Grant Thornton International IFRS team has published IFRS Viewpoint – Accounting for cryptocurrencies – the basics.

The IFRS Viewpoint series provides insights on applying IFRS in challenging situations. Each edition will focus on an area where the standards have proved difficult to apply or lack guidance.

This edition provides guidance on some of the basic issues encountered in accounting for cryptocurrencies, focusing on the accounting for the holder. A future IFRS Viewpoint will explore other more complex issues, such as those relating specifically to cryptocurrency miners.

The issue

The popularity of cryptocurrencies has soared in recent years, yet they do not fit easily within IFRS’ financial reporting structure. For example, an approach of accounting for holdings of cryptocurrencies at fair value through profit or loss may seem intuitive but is incompatible with the requirements of IFRS in most circumstances. This IFRS Viewpoint explores the acceptable methods of accounting for holdings in cryptocurrencies while touching upon other issues that may be encountered.