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Welcome to our Transfer Pricing blog series! As global commerce and technology continue to expand, the movement of goods, services and intellectual property across borders becomes increasingly intricate, making transfer pricing a critical focal point for multinational enterprises and tax authorities. Our series will help your company focus on remaining proactive, not reactive, to today's dynamic global market. We will provide in-depth insights and practical guidance on how to navigate the regulatory landscape, achieve operational and tax efficiency and stay ahead an arm's length.
Smoother sailing for supply chains through the lens of trade and tax
Kristin Bohl, Brad Slattery, Chase Podsaid and Craig Stronberg.
September 26, 2024.
In today's global business landscape, volatility, uncertainty, complexity and ambiguity—collectively known as VUCA—are more pronounced than ever. The post-Covid era has dismantled traditional geopolitical guardrails, creating a more challenging trade and tax environment, including supply scarcity and a general decrease in trust. Adopting a multidisciplinary approach to these changes from trade, tax and supply chain management perspectives is important for companies to remain competitive, mitigate risks and unforeseen tax costs, and ensure compliance in a rapidly evolving global landscape.
Navigating change: Steer your company through the effects of country-by-country reporting
David Ernick and Kristina Novak.
August 23, 2024.
Our latest blog discusses the significance of country-by-country reporting (CbCR) and the challenges faced by multinational enterprises (MNEs) in complying with the CbCR Safe Harbor and Public CbCR requirements. The CbCR Safe Harbor allows MNEs to reduce their obligations under global minimum tax rules, while Public CbCR requires MNEs to disclose their CbCR data to the public. Learn actionable steps that companies can take to ensure compliance with these reporting frameworks, including understanding the implications of CbCR, evaluating the CbCR Safe Harbor, preparing for Public CbCR, protecting sensitive information, and consulting with professionals.
Transfer Pricing and the Pillar Two Transitional CbCR Safe Harbor: What do you need to know to transform?
Brian Burt, David Ernick, Kristina Novak, Kartikeya Singh and Andrew Hwang.
February 13, 2024.
The Transitional Country-by-Country report (CbCR) Safe Harbor under Pillar Two offers multinational enterprises (MNEs) a temporary means to reduce or eliminate top-up taxes in certain jurisdictions by meeting one of three criteria. This safe harbor, applicable for fiscal years beginning on or before December 31, 2026, helps MNEs lower compliance obligations and data requirements, provided they use Qualified Financial Statements to prepare their CbCR. Recent guidance emphasizes the importance of accurate data, consistent application, and alignment with transfer pricing policies to qualify for this safe harbor and avoid potential tax disputes.
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