Presentation delivered by Cynthia Hoffman, International Tax Director, Bloomin' Brands, Inc. and Niraja Srinivasan, Executive Director, Transactions Pricing, Dell Inc.
Presentation delivered by Camille Evans, International Tax Director, Eastman Chemical Company and Tasheaya Warren Ellison, Senior Tax Attorney – Tax Dispute Resolution, Shell Oil Company at the marcus evans Tax Officers Summit 2016 in FL.
Presentation delivered by Angie Pulley, Director, Income Tax, Planning and Accounting, Coca Cola Bottling Company at the Tax Officers Summit 2016 in FL
Tax management within multinational enterprises (MNEs) has never been more challenging. 'Getting to grips with the BEPS Action Plan' is the latest Grant Thornton report exploring the OECD’s planned overhaul of the international tax system, what it means for businesses and how they can prepare.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
International Tax Planning after BEPS - A Country SpotlightTIAG_Alliance
The OECD initiative against “Base Erosion and Profit Shifting” was
commissioned by the G-20 in 2013. Final deliverables were presented to the G-20 in November 2015.
“Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. BEPS is of major significance for developing countries due to their heavy reliance on corporate income tax, particularly from multinational enterprises (MNEs.)”
Creators and Presenters:
• Russell Brown, LehmanBrown, China
• Florence Bastin, Fiduciaire du Grand-Duché de
Luxembourg S.à r.l. (FLUX)
• Fabrice Rymarz, Racine, France
• Simone Hennessy, HSOC, Ireland
• Fuad Saba, FGMK, Chicago, USA (Moderator)
Presentation delivered by Camille Evans, International Tax Director, Eastman Chemical Company and Tasheaya Warren Ellison, Senior Tax Attorney – Tax Dispute Resolution, Shell Oil Company at the marcus evans Tax Officers Summit 2016 in FL.
Presentation delivered by Angie Pulley, Director, Income Tax, Planning and Accounting, Coca Cola Bottling Company at the Tax Officers Summit 2016 in FL
Tax management within multinational enterprises (MNEs) has never been more challenging. 'Getting to grips with the BEPS Action Plan' is the latest Grant Thornton report exploring the OECD’s planned overhaul of the international tax system, what it means for businesses and how they can prepare.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
International Tax Planning after BEPS - A Country SpotlightTIAG_Alliance
The OECD initiative against “Base Erosion and Profit Shifting” was
commissioned by the G-20 in 2013. Final deliverables were presented to the G-20 in November 2015.
“Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. BEPS is of major significance for developing countries due to their heavy reliance on corporate income tax, particularly from multinational enterprises (MNEs.)”
Creators and Presenters:
• Russell Brown, LehmanBrown, China
• Florence Bastin, Fiduciaire du Grand-Duché de
Luxembourg S.à r.l. (FLUX)
• Fabrice Rymarz, Racine, France
• Simone Hennessy, HSOC, Ireland
• Fuad Saba, FGMK, Chicago, USA (Moderator)
International Tax Planning as Viewed through the Eyes of BEPSLewis Rice
Lewis Rice attorney Timothy G. Stewart co-presented to the St. Louis International Tax Group on the OECD's efforts to address Base Erosion and Profit Shifting.
In July 2013 the OECD unveiled the Action Plan on Base Erosion and Profit Shifting (BEPS), which aims to develop a new set of standards to prevent double non-taxation and ensure that profits are taxed where they are actually generated. By Grace Perez-Navarro, Deputy Director, and Raffaele Russo, Head of the BEPS Project, Centre for Tax Policy and Administration.
Exchange on request, automatic exchange of financial account information and TRACE (Treaty Relief and Compliance Enhancement), spontaneous exchange of rulings, country-by-country reporting, voluntary disclosure programmes.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration and Monica Bhatia, Head, Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
International Business Transactions has indeed made the world smaller and more developed. However due to the free cross boundary transactions, business entities are now able to generate revenue and not pay the appropriate taxes in their respective countries.
The G20 Countries had assigned OECD to come up with some non tax evasion rules so that the countries of the world may accept the same without any dispute.
This presentation covers the BEPS Rules suggested by OECD and explains the changes in Tax Laws that India has incorporated in order to align with BEPS and to curb Tax Evasion.
This presentation was performed by my GMCS Team during the GMCS 2 Course at Mangalore Branch of SIRC of ICAI.
HDG - Base Erosion & Profit Shifting (BEPS) - Conceptual Analysis & Country b...Hitesh Gajaria
How Tax Authorities are Globally Coming Together to Combat the Digital Disruption
World's Largest Cab Co ... Owns No Cabs! - (Uber)
Largest Accommodation Provider .... Owns No Real Estate! (Airbnb)
World's Most Valuable Retailer .. Has No Inventory!
World's Largest Movie House ... Owns No Cinemas! (NetFlix)
Most Popular Media Owner .. Creates No Content! (Facebook)
Whether you represent a large corporation, a small business, or a not-for-profit organization, it can be difficult to stay up to date on current accounting topics. Join Timothy McLaughlin, Vincent Leo, and Michael Giess for an overview of changes that may affect your organization and how to apply the most recent standards and guidance.
Automatic exchange of financial account informationnztaxpolicy
Presentation about New Zealand's proposed implementation of the GE20/OECD automatic exchange of information (AEOI) initiative.
Delivered on 7 March 2016 at Chartered Accountants Australia and New Zealand, Auckland, New Zealand.
For more information see:
http://taxpolicy.ird.govt.nz/topical-issues/implementing-aeoi
Automatic exchange of information (AEOI) - November 2016nztaxpolicy
Presentation delivered in November 2016 (Wellington - 4th November, Auckland - 9th November, webinar - 18th November) aimed at financial institutions and covered the practical implementation and technical issues for the Common Reporting Standard.
Testimony: Kansas Tax Modernization: A Framework for Stable, Fair, Pro-growth...Kevin Kaufman
Testimony to: Kansas’ Senate Committee on Assessment and Taxation; and Kansas’ House Committee on Taxation
Presenting: Kansas Tax Modernization: A Framework for Stable, Fair, Pro-growth Reform
International Tax Reform - Tax Cuts and Jobs Act of 2017gppcpa
This presentation is an overview of the new tax law and how it impacts international taxation including such topics as the Participation Exemption, Transition Tax, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, Base Erosion and Anti-Abuse Tax, and Interest Deductibility.
Diez trampas en la travesía ágil por Nelice Heck y Gabriel GavassoDiana Pinto
Sabemos de la importancia de utilización de los princípios ágiles en desarrollo de software y cuan rápido podemos adaptarnos en casos de cambios. Mucho se habla sobre eso, pero su utilización puede ocasionar trampas en nuestra trayectoria de aplicación de estos principios.
En esta charla vamos hablar de las 10 trampas más comunes que ocurren en proyectos y clientes que empiezan com ágil.
Nelice Heck
@NeliceH
LinkedIn: http://bit.ly/1XbqDh9
Gabriel Gavasso
@gabrielgavasso
LinkedIn: http://bit.ly/1Rz9B8K
International Tax Planning as Viewed through the Eyes of BEPSLewis Rice
Lewis Rice attorney Timothy G. Stewart co-presented to the St. Louis International Tax Group on the OECD's efforts to address Base Erosion and Profit Shifting.
In July 2013 the OECD unveiled the Action Plan on Base Erosion and Profit Shifting (BEPS), which aims to develop a new set of standards to prevent double non-taxation and ensure that profits are taxed where they are actually generated. By Grace Perez-Navarro, Deputy Director, and Raffaele Russo, Head of the BEPS Project, Centre for Tax Policy and Administration.
Exchange on request, automatic exchange of financial account information and TRACE (Treaty Relief and Compliance Enhancement), spontaneous exchange of rulings, country-by-country reporting, voluntary disclosure programmes.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration and Monica Bhatia, Head, Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
International Business Transactions has indeed made the world smaller and more developed. However due to the free cross boundary transactions, business entities are now able to generate revenue and not pay the appropriate taxes in their respective countries.
The G20 Countries had assigned OECD to come up with some non tax evasion rules so that the countries of the world may accept the same without any dispute.
This presentation covers the BEPS Rules suggested by OECD and explains the changes in Tax Laws that India has incorporated in order to align with BEPS and to curb Tax Evasion.
This presentation was performed by my GMCS Team during the GMCS 2 Course at Mangalore Branch of SIRC of ICAI.
HDG - Base Erosion & Profit Shifting (BEPS) - Conceptual Analysis & Country b...Hitesh Gajaria
How Tax Authorities are Globally Coming Together to Combat the Digital Disruption
World's Largest Cab Co ... Owns No Cabs! - (Uber)
Largest Accommodation Provider .... Owns No Real Estate! (Airbnb)
World's Most Valuable Retailer .. Has No Inventory!
World's Largest Movie House ... Owns No Cinemas! (NetFlix)
Most Popular Media Owner .. Creates No Content! (Facebook)
Whether you represent a large corporation, a small business, or a not-for-profit organization, it can be difficult to stay up to date on current accounting topics. Join Timothy McLaughlin, Vincent Leo, and Michael Giess for an overview of changes that may affect your organization and how to apply the most recent standards and guidance.
Automatic exchange of financial account informationnztaxpolicy
Presentation about New Zealand's proposed implementation of the GE20/OECD automatic exchange of information (AEOI) initiative.
Delivered on 7 March 2016 at Chartered Accountants Australia and New Zealand, Auckland, New Zealand.
For more information see:
http://taxpolicy.ird.govt.nz/topical-issues/implementing-aeoi
Automatic exchange of information (AEOI) - November 2016nztaxpolicy
Presentation delivered in November 2016 (Wellington - 4th November, Auckland - 9th November, webinar - 18th November) aimed at financial institutions and covered the practical implementation and technical issues for the Common Reporting Standard.
Testimony: Kansas Tax Modernization: A Framework for Stable, Fair, Pro-growth...Kevin Kaufman
Testimony to: Kansas’ Senate Committee on Assessment and Taxation; and Kansas’ House Committee on Taxation
Presenting: Kansas Tax Modernization: A Framework for Stable, Fair, Pro-growth Reform
International Tax Reform - Tax Cuts and Jobs Act of 2017gppcpa
This presentation is an overview of the new tax law and how it impacts international taxation including such topics as the Participation Exemption, Transition Tax, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, Base Erosion and Anti-Abuse Tax, and Interest Deductibility.
Diez trampas en la travesía ágil por Nelice Heck y Gabriel GavassoDiana Pinto
Sabemos de la importancia de utilización de los princípios ágiles en desarrollo de software y cuan rápido podemos adaptarnos en casos de cambios. Mucho se habla sobre eso, pero su utilización puede ocasionar trampas en nuestra trayectoria de aplicación de estos principios.
En esta charla vamos hablar de las 10 trampas más comunes que ocurren en proyectos y clientes que empiezan com ágil.
Nelice Heck
@NeliceH
LinkedIn: http://bit.ly/1XbqDh9
Gabriel Gavasso
@gabrielgavasso
LinkedIn: http://bit.ly/1Rz9B8K
"Oz de repente acorda e quando se vê ao espelho fica em choque. O corpo que supostamente a sua alma está, não é o dele. Gil, eufórico, entra no quarto e Oz aos berros devido há situação toda em que se encontra. Em que corpo estará Oz? Por que é que Gil entra no quarto daquela maneira? Isto é uma situação complicada para dois e existe uma solução para a consertar e sabem qual é? O melhor é ler a fic para descobrirem a situação engraçada e embaraçosa que terão que fazer para resolver os seus problemas."
"Utilizing UV Curing in Decorating Plastic Substrates 101" presented by Steve Hatkevich, Director of R&D, American Trim LLC at RadTech UV & EB Technology Expo & Conference 2014. To learn more about UV & EB curing, visit http://www.radtech.org.
In 2016, the Financial Accounting Standards Board (FASB) released 20 accounting standards updates (ASUs). Among the more significant were changes to leasing, financial instruments and the not-for-profit reporting model.
Despite the completion of many significant projects, the FASB will likely remain active during 2017. Presently, it has 26 active projects, the most significant of which may be considered the proposed changes to hedge accounting originally issued in the third quarter of 2016. During the fourth quarter of 2016 and first couple weeks of 2017, the FASB issued seven accounting standards updates.
Accounting Technical Updates: What has the FASB been focused on?McKonly & Asbury, LLP
This webinar will present a high level overview of the more significant projects and technical updates of the FASB. The topics covered in this presentation will include revenue recognition, leases, business combinations, Goodwill & Intangibles, Compensation and Not-for-profit Entities.
The biggest accounting changes coming out of the third quarter affected not-for-profit organizations, but other projects received minor updates, too. In addition, several exposure drafts have been issued, including the expected exposure draft of targeted improvements to hedge accounting.
The second quarter of 2017 brought only two accounting standards and might represent the calm before the next storm. The Financial Accounting Standards Board (FASB) currently has 24 projects in various stages of development on its agenda and 10 research projects.
Major projects, including accounting updates to hedging, consolidation and the disclosure framework are still in the works, and research projects indicate that the FASB may be taking a closer look at accounting for intangibles, distinguishing liabilities from equity, inventory and cost of sales, subsequent accounting for goodwill and financial performance.
Politics and Treasury: How the New Administration May Impact Treasury in 2017Elena Oliveira
Last year’s US election campaign offered many promises that were expected to significantly affect corporate finance. As the new administration implements change, several impacts can be expected for CFOs and Treasurers. View our recorded webinar during which we discuss the potential effects on corporate treasury and how your team can be prepared.
Addressing international corporate tax evasion an analysis of the oecd acti...Florian Marchal
This presentation aims to describe the issue around the international tax standards which are not adapted to the ongoing changes in the economy, creating loopholes and opportunities for base erosion and profit shifting. Such issue is currently being tackled and is taking place in a context where the OECD established the BEPS action plan.
This work is based around the following research question: Is the BEPS initiative an appropriate approach to harmonize the international tax system and consequently reduce base erosion and profit shifting?
Director: Professor Jean-Pierre De Laet
Assessor and jury president: Professor Pascal Minne
OBJECTIVE
OECD Inclusive Framework released a public consultation document on matters where its members seek input from stakeholders in conducting this 2020 review. This webinar shall touch upon the issues relating to implementation, scope and content of CbC Reporting set out in the document for public consultation.
Offering insights into Accounting Standards Updates (ASUs), the new ASUs are explained with particular emphasis on standards that became effective for the 2017 calendar year, will take effect in 2018, or have been issued in 2017 and 2018, but are not effective until 2019 or thereafter.
Reporting challenges for Office of Finance - Accounting Finance Tax Risk Mana...paul young cpa, cga
This presentation discusses the focus for Office of Finance (Accounting, Finance Planning and Analysis, Internal Controls, Taxation and Risk Management) for 2017.
New laws that affect transfer pricing went into effect in 2018 that will have an effect on 2019 financial reporting. Countries with activities in Denmark, Argentina, Brazil, Saudi Arabia, and Great Britain should be aware of these recent transfer pricing developments.
We remain in a relatively quiet time for changes in accounting and reporting standards affecting not-for-profit organizations, notwithstanding larger proposals affecting the intermediate and longer term.
Companies with a growing globalized workforce may be incurring significant risks in the operation of their compensation programs. Taxing authorities around the world are looking for additional sources of tax revenues by way of underpaid employment taxes, underpaid withholdings, incorrect payroll deductions, and more. As a result, companies are being scrutinized more than ever creating substantial legal and financial risk.
Join us for an exclusive presentation from the world's leading compensation planning & tax experts, Ernst & Young, as they share inside strategies and best practices they have used to help companies around the world save millions in fines, penalties and judgments.
In this exclusive webinar you will learn:
○ How to minimize employment and labor law risks exposing employers to potential underpaid employment taxes, litigation and related settlement costs;
○ How to identify possible underpaid withholding and employer social security taxes, penalties and fines due to payroll non-compliance;
○ How to avoid payroll reporting errors due to mis-alignment with corporate income tax deduction policy for compensation costs.
Restructuring global compensation pay strategies that ignore regional norms and fail in key emerging markets;
Ahead of the marcus evans CFO Summit 2024, Erik Saito discusses what technology CFOs can utilise to improve financial reporting accuracy, make more strategic decisions and mitigate risks.
Ahead of the marcus evans Chief Procurement Officer Summit 2023, read here an interview with Ward Karson discussing what tools CPOs can utilize to deliver improved performance.
Michael McRoberts and George Skillin of Chartertech Pty Ltd, a sponsor company at the marcus evans CFO Summit 2023, discuss how financial processes can improve with tools such as RPA and AI.
Ahead of the marcus evans Chief Procurement Officer Summit 2023, read here an interview with Jag Lamba discussing process adaptability and how CPOs need to prepare for what lies ahead.
Lutz Finger, President, Product & Development at Marpai, an AI-powered health plan services provider (Third Party Administrator for Self-funded health plans), was interviewed ahead of the marcus evans CFO Summit XLI 2022, and discusses how CFOs can leverage the power of the most advanced AI to create the healthiest member population with the greatest cost efficiency within their health plan budget.
Ahead of the marcus evans Chief Procurement Officer Summit 2022, read here an interview with Cary David discussing how the supply chain function can be the engine for change in a growing company.
Ahead of the marcus evans Tax Officers Summit 2022, read here an interview with Robert Lenius discussing the opportunities and capabilities available to the tax function today.
Ahead of the marcus evans Chief Procurement Officer Summit 2022, read here an interview with Ward Karson discussing strategies for CPOs to succeed on the digital procurement journey.
Ahead of the marcus evans Tax Officers Summit 2022, read here an interview with Chris Roetheli on what strategies and programs would help the tax function drive ESG impact.
Presentation delivered by Victor C. Barnes, Global CFO, The McDonald’s Division, The Coca-Cola Company at the marcus evans CFO Summit Spring 2019 held in Palm Beach FL.
Dual Keynote Presentation delivered by Dr Mark Frigo, Director, Center for Strategy, Execution & Valuation; Strategic Risk Management Lab, DePaul University and E. Terry Groff, Former CEO & President, Reading Bakery Systems at the marcus evans CFO Summit Spring 2019 held in Palm Beach, FL
[Note: This is a partial preview. To download this presentation, visit:
https://www.oeconsulting.com.sg/training-presentations]
Sustainability has become an increasingly critical topic as the world recognizes the need to protect our planet and its resources for future generations. Sustainability means meeting our current needs without compromising the ability of future generations to meet theirs. It involves long-term planning and consideration of the consequences of our actions. The goal is to create strategies that ensure the long-term viability of People, Planet, and Profit.
Leading companies such as Nike, Toyota, and Siemens are prioritizing sustainable innovation in their business models, setting an example for others to follow. In this Sustainability training presentation, you will learn key concepts, principles, and practices of sustainability applicable across industries. This training aims to create awareness and educate employees, senior executives, consultants, and other key stakeholders, including investors, policymakers, and supply chain partners, on the importance and implementation of sustainability.
LEARNING OBJECTIVES
1. Develop a comprehensive understanding of the fundamental principles and concepts that form the foundation of sustainability within corporate environments.
2. Explore the sustainability implementation model, focusing on effective measures and reporting strategies to track and communicate sustainability efforts.
3. Identify and define best practices and critical success factors essential for achieving sustainability goals within organizations.
CONTENTS
1. Introduction and Key Concepts of Sustainability
2. Principles and Practices of Sustainability
3. Measures and Reporting in Sustainability
4. Sustainability Implementation & Best Practices
To download the complete presentation, visit: https://www.oeconsulting.com.sg/training-presentations
Discover the innovative and creative projects that highlight my journey throu...dylandmeas
Discover the innovative and creative projects that highlight my journey through Full Sail University. Below, you’ll find a collection of my work showcasing my skills and expertise in digital marketing, event planning, and media production.
Digital Transformation and IT Strategy Toolkit and TemplatesAurelien Domont, MBA
This Digital Transformation and IT Strategy Toolkit was created by ex-McKinsey, Deloitte and BCG Management Consultants, after more than 5,000 hours of work. It is considered the world's best & most comprehensive Digital Transformation and IT Strategy Toolkit. It includes all the Frameworks, Best Practices & Templates required to successfully undertake the Digital Transformation of your organization and define a robust IT Strategy.
Editable Toolkit to help you reuse our content: 700 Powerpoint slides | 35 Excel sheets | 84 minutes of Video training
This PowerPoint presentation is only a small preview of our Toolkits. For more details, visit www.domontconsulting.com
3.0 Project 2_ Developing My Brand Identity Kit.pptxtanyjahb
A personal brand exploration presentation summarizes an individual's unique qualities and goals, covering strengths, values, passions, and target audience. It helps individuals understand what makes them stand out, their desired image, and how they aim to achieve it.
VAT Registration Outlined In UAE: Benefits and Requirementsuae taxgpt
Vat Registration is a legal obligation for businesses meeting the threshold requirement, helping companies avoid fines and ramifications. Contact now!
https://viralsocialtrends.com/vat-registration-outlined-in-uae/
LA HUG - Video Testimonials with Chynna Morgan - June 2024Lital Barkan
Have you ever heard that user-generated content or video testimonials can take your brand to the next level? We will explore how you can effectively use video testimonials to leverage and boost your sales, content strategy, and increase your CRM data.🤯
We will dig deeper into:
1. How to capture video testimonials that convert from your audience 🎥
2. How to leverage your testimonials to boost your sales 💲
3. How you can capture more CRM data to understand your audience better through video testimonials. 📊
RMD24 | Retail media: hoe zet je dit in als je geen AH of Unilever bent? Heid...BBPMedia1
Grote partijen zijn al een tijdje onderweg met retail media. Ondertussen worden in dit domein ook de kansen zichtbaar voor andere spelers in de markt. Maar met die kansen ontstaan ook vragen: Zelf retail media worden of erop adverteren? In welke fase van de funnel past het en hoe integreer je het in een mediaplan? Wat is nu precies het verschil met marketplaces en Programmatic ads? In dit half uur beslechten we de dilemma's en krijg je antwoorden op wanneer het voor jou tijd is om de volgende stap te zetten.
What are the main advantages of using HR recruiter services.pdfHumanResourceDimensi1
HR recruiter services offer top talents to companies according to their specific needs. They handle all recruitment tasks from job posting to onboarding and help companies concentrate on their business growth. With their expertise and years of experience, they streamline the hiring process and save time and resources for the company.
Kseniya Leshchenko: Shared development support service model as the way to ma...Lviv Startup Club
Kseniya Leshchenko: Shared development support service model as the way to make small projects with small budgets profitable for the company (UA)
Kyiv PMDay 2024 Summer
Website – www.pmday.org
Youtube – https://www.youtube.com/startuplviv
FB – https://www.facebook.com/pmdayconference
Premium MEAN Stack Development Solutions for Modern BusinessesSynapseIndia
Stay ahead of the curve with our premium MEAN Stack Development Solutions. Our expert developers utilize MongoDB, Express.js, AngularJS, and Node.js to create modern and responsive web applications. Trust us for cutting-edge solutions that drive your business growth and success.
Know more: https://www.synapseindia.com/technology/mean-stack-development-company.html
"𝑩𝑬𝑮𝑼𝑵 𝑾𝑰𝑻𝑯 𝑻𝑱 𝑰𝑺 𝑯𝑨𝑳𝑭 𝑫𝑶𝑵𝑬"
𝐓𝐉 𝐂𝐨𝐦𝐬 (𝐓𝐉 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
𝐓𝐉 𝐂𝐨𝐦𝐬 provides unlimited package services including such as Event organizing, Event planning, Event production, Manpower, PR marketing, Design 2D/3D, VIP protocols, Interpreter agency, etc.
Sports events - Golf competitions/billiards competitions/company sports events: dynamic and challenging
⭐ 𝐅𝐞𝐚𝐭𝐮𝐫𝐞𝐝 𝐩𝐫𝐨𝐣𝐞𝐜𝐭𝐬:
➢ 2024 BAEKHYUN [Lonsdaleite] IN HO CHI MINH
➢ SUPER JUNIOR-L.S.S. THE SHOW : Th3ee Guys in HO CHI MINH
➢FreenBecky 1st Fan Meeting in Vietnam
➢CHILDREN ART EXHIBITION 2024: BEYOND BARRIERS
➢ WOW K-Music Festival 2023
➢ Winner [CROSS] Tour in HCM
➢ Super Show 9 in HCM with Super Junior
➢ HCMC - Gyeongsangbuk-do Culture and Tourism Festival
➢ Korean Vietnam Partnership - Fair with LG
➢ Korean President visits Samsung Electronics R&D Center
➢ Vietnam Food Expo with Lotte Wellfood
"𝐄𝐯𝐞𝐫𝐲 𝐞𝐯𝐞𝐧𝐭 𝐢𝐬 𝐚 𝐬𝐭𝐨𝐫𝐲, 𝐚 𝐬𝐩𝐞𝐜𝐢𝐚𝐥 𝐣𝐨𝐮𝐫𝐧𝐞𝐲. 𝐖𝐞 𝐚𝐥𝐰𝐚𝐲𝐬 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐬𝐡𝐨𝐫𝐭𝐥𝐲 𝐲𝐨𝐮 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐚 𝐩𝐚𝐫𝐭 𝐨𝐟 𝐨𝐮𝐫 𝐬𝐭𝐨𝐫𝐢𝐞𝐬."
2. Transfer Pricing Highlights
Base Erosion & Profit Shifting (“BEPS”)
OECD Published 15 Actions/Guidelines
Proposed Treasury Regulations Under
Section 385
Related Party Financing Arrangements
2
3. Base Erosion & Profit Shifting (“BEPS”)
Broadly Aimed at Aligning Taxable Income with Value Creation
4 Actions Related Specifically to Transfer Pricing
Action 13 – Transfer Pricing Documentation & Country by Country
Reporting
o Aimed at Reporting Transparency
Action 8 – Intangible Asset Structuring
Action 9 – Risk and Capital
Action 10 – High Risk Transactions
o Actions 8-10 Aimed at setting Standards for Substance
3
4. BEPS Action 13 Guidance
Action 13 focuses on Transfer Pricing Documentation and Includes the
Country-by-Country Report (CbCR).
Three-tier framework
providing information on
global allocation of income,
economic activity and
intercompany pricing across
a company’s global
operations.
Applies to all multinational
enterprises (MNEs) with
aggregate annual revenue
in excess of $900m.
Tier One: Master File
Overview of Business and Tax/TP Model, IP, Key Drivers of
Profit – by Product Line and Geography
Tier Two: Local File
Tier Three: Country by Country (“CBCR”)
4
Summary of Financial + HR Data to Calculate Allocation of
Income by Jurisdiction
Legal Entity TP Report, Tying LE Pre-Tax Income to its
Operations and Risk Profile
5. Country by Country Reporting
In General:
Tables 1 and 2 can be publicly disclosed (UK Proposal, Sept 2016)
Voluntary Disclosure May Push Submission timeline to early 2017 (FYE and
country dependent)
Disclosure formats and info sharing mechanism still not clear
Required to reconcile with regulatory and statutory reporting
Build Tools to assist with reconciling
Timing of statutory financial statements may be too late to comply
Tie all together with 5471 & Transfer pricing documentation and reports,
legal documentation and accounting
5
6. Country by Country Reporting
IRS issued final regulations, effective for US MNE parent with tax
year beginning on or after June 30, 2016
IRS issued draft Form 8975 in August 2016
For tax years beginning before June 30, 2016, US ultimate
parent can voluntarily file
Required to reconcile with 5471, statutory F/S filings, and
Regulatory Filings
Building Tools to map US GAAP or Local Stat accounts to CBCR
fields
Timing of CBCR submission and statutory financial statements may
be too late to comply
Standing up X-functional Teams for multiple CBCR prep each year
6
What are
companies
doing now?
7. Country by Country Reporting
Assessing Audit Risk/Defense
Ratio Comparisons
Formulary Apportionment scenarios
Anticipating questions that will come
from tax authorities
Drafting responses and TP
documentation
7
What are
companies
doing now?
8. BEPS – What’s Next?
Actions 8, 9, 10 Substance
Transfer Pricing Outcomes and Value Creation
Action 8 -
Intangibles
New definition
of intangibles
New guidance
on HTV
intangibles
Action 9 – Risk &
Capital
Control over risk
Capacity &
functionality to
manage risks
Action 10 – High-
risk Transactions
Intra-group
Services
Low-tax
Jurisdictions
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9. US 482 Regs vs. OECD BEPS Positions on IP
482-7 – Cost Sharing
based on Reasonably
Anticipated Benefits
482-9 – Cost Plus
Remuneration for R&D
Service Providers; Legal
& Economic Ownership
separation is respected
OECD BEPS
Focus on Value
Creation
Economic Ownership
asserted over Legal
Ownership
Value-creating entities
across the supply chain
are entitled to share of
profit
US 482 and OECD BEPS
A Balancing Act
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10. Monitoring BEPS … What’s Hot, What Not (Yet)
Action 1 Taxation of Digital Economy
Action 2 Hybrid Mismatches
Action 3 CFC Rules
Action 4 Interest Deductions
Action 5 Counter Harmful Tax Practices
Action 6 Abusing Treaty Benefits
Action 7 Artificial Avoidance of PE
Action 8 Intangible Asset Structures
Action 9 Risk and Capital
Action 10 Other High Risk Transactions
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12. Transfer Pricing Highlights
Base Erosion & Profit Shifting (“BEPS”)
OECD Published 15 Actions/Guidelines
Proposed Treasury Regulations Under
Section 385
Related Party Financing Arrangements
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13. Proposed Treasury Regulations – Section 385
Contemporaneous documentation requirement (Prop. Reg. Sec. 1.385-2)
Applies to “large expanded groups to “expanded group indebtedness” (“EGI”)
Effective for debt instruments issued on or after date finalized regulations are issued
Documentation prepared within 30 days after issue date (or date becomes EGI)
Penalty for failure is recharacterization of debt as equity
Identify WHO performs documentation
Satisfaction of document requirements does not ensure debt treatment (it is a
minimum standard)
“Significant Modification” – deemed new debt issuance
Issued April 4, 2016 Application to Related Party Financing
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14. “Expanded Group Indebtedness”
Add Other Entities, including held indirectly
Foreign
Tax
Exempt
Affiliated Group (1504(a))
Ownership of 80%
vote, OR
Ownership of 80%
value
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16. Documentation Requirements –1.385-2(b)(2)
Legally binding
obligation
Creditor’s right to
enforce terms
Evidence of ability
to repay at
issuance & annually
Timely interest &
principal payments
with default
provisions
Four categories of
documents required for
related party financing
instruments to be
respected as debt
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17. Documentation Requirements -1.385-2(b)(2)
Special Documentation Required – Revolvers & Cash Pools
Enabling and governing documents and agreements must be maintained
• BOD resolutions, credit agreements, etc.
• On-going operations of the arrangement or services
Trade Payables? Open Accounts?
How much documentation is enough?
Controlled Partnerships (> 80% of capital and profits interest)
Treated as members of the expanded group
Treated as an partnership equity interest if debt treated as stock
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18. Other Issues Facing TP
Intra-company Management fees
Non-Deductible Expenses (Brazil management fees)
Documentation Supporting Benefits (Mexico, India)
Local taxes (VAT) on IC charges can drive up real expenses
Withholding tax documentation
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