BEPS contract review: Why it matters
July 12 | 2 p.m. ET | 18:00 GMT
Host: Mark Nehoray, partner, Deloitte Tax LLP
1 Overview CPE credit | Taxes
The OECD's BEPS Actions 8-10, covering Transfer Pricing Guidelines, recommend granular functional and risk analysis to determine whether a controlled transaction has economic substance. Why is a review of intercompany transaction contracts the starting point? We'll discuss:
- Broad categories of risk and the six-step process for accurately delineating each transaction's economically significant risks.
- How contracts can provide evidence of who is managing and controlling significant risks, and the three elements of risk management.
- How contracts can provide evidence of appropriate control over day-to-day risk mitigation, especially when mitigation activities are outsourced.
- Testing the contractual allocation of risk.
Learn more about this vital and highly complex area of transfer pricing tax compliance.