{"id":2718,"date":"2023-06-14T16:16:06","date_gmt":"2023-06-14T14:16:06","guid":{"rendered":"https:\/\/www.tomato.ch\/blog\/?p=2718"},"modified":"2023-06-14T16:16:06","modified_gmt":"2023-06-14T14:16:06","slug":"transfer-pricing-5-tips","status":"publish","type":"post","link":"https:\/\/www.tomato.ch\/blog\/2023\/06\/transfer-pricing-5-tips\/","title":{"rendered":"Transfer Pricing: 5 Tips"},"content":{"rendered":"\n

David McDonald from PwC suggests in TMI (Treasury Management International) 5 things that help you stay active and up to date on transfer pricing:<\/p>\n\n\n\n

    \n
  1. Statement:<\/strong> Group Tax is responsible for transfer pricing. Treasury sets and applies the policies.
    Risk<\/strong>: Without clear communication between the treasury and tax departments, there is a risk of penalties.<\/li>\n\n\n\n
  2. Statement<\/strong>: We have a great policy established and 2017 by a specialist and run it this way.
    Risk<\/strong>: In 2020, the OECD published detailed guidelines focused on IC-loans, cash pool, guarantees, hedging, and captive insurance. We stayed tuned and made the necessary updates.<\/li>\n\n\n\n
  3. Statement<\/strong>: We have benchmarks; we use fixed rates from 2020.
    Risk<\/strong>: Prices have changed significantly in the last 12 months. The use of outdated benchmarks is dangerous.<\/li>\n\n\n\n
  4. Statement<\/strong>: The excellent bank relationship ensures indicative quotes for IC-transactions.
    Risk<\/strong>: OECD guidance state clearly that bank quotes are not an acceptable form because tax authority can\/will ignore them. Use a transfer pricing benchmark that can be defended.<\/li>\n\n\n\n
  5. Statement<\/strong>: Performing detailed analyses on every loan and related party.
    Risk<\/strong>: IC-Loan amount\/size matters for tax at risk. A 5m IC-loan is less at risk than a 50m IC-loan. Use a standard policy that applies to 80-90% of intra-group loans and only evaluate the largest transactions.<\/li>\n<\/ol>\n\n\n\n

    Details in the\u00a0PwC report on TMI<\/a>\u00a0(Login required, report available at Tomato)<\/p>\n

    Tweet<\/a><\/div>","protected":false},"excerpt":{"rendered":"

    David McDonald from PwC suggests in TMI (Treasury Management International) 5 things that help you stay active and up to date on transfer pricing: Details in the\u00a0PwC report on TMI\u00a0(Login required, report available at Tomato) Tweet<\/p>\n