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What is Base Erosion Profit Shifting (BEPS)?
As we can see that international taxation is changing rapidly as per the different norms made by the government and unilateral arrangements as designed by individual countries both are intended to tackle concerns over BEPS and perceive international tax avoidance of high profile multinational organizations.
FAQ
Common List Of Questioner That Our Customer Ask From Us -Solved !
What are the list of assistance provided by BIATConsultant ?
Following assistance will be provided by our side-
1. We will assist upon the overall strategy of MNE group on the basis of BEPS provision and also to comply with the new requirements that are arising product wise.
2. We can assist in analysing intangibles and also whether the group members are contributing towards development, maintenance, protection and exploitation of intabiles which are being awarded appropriately in line with significant people’s function.
3. To review and evaluate the company readiness on TP compliances and accordingly we assist on the documentation which are required.
1. We will assist upon the overall strategy of MNE group on the basis of BEPS provision and also to comply with the new requirements that are arising product wise.
2. We can assist in analysing intangibles and also whether the group members are contributing towards development, maintenance, protection and exploitation of intabiles which are being awarded appropriately in line with significant people’s function.
3. To review and evaluate the company readiness on TP compliances and accordingly we assist on the documentation which are required.
BEPS- TP Achievement Points
After all analyzation and recommendation of BEPS and worldwide in depth scrutiny by the tax authorities mainly involves intangible transactions. Tax authorities are likely to draw inference and support from OECD and BEPS guidelines to determine return from intangibles. This helps us to guide how to analyze Intellectual Property Rights, brands etc. and how they are positioned whether all group members are contributing towards development, enhancement, maintenance, protection and exploitation of intangibles which helps to determine-
1. Location of IPR and place of conceptualization and development of IPR.
2. Legal ownership or beneficiary ownership of intangibles and related payment.
3. Requires providing an overview of MNE’s global chain.
4. Identify whether the revenue and profit generated from all jurisdictions are proportionate with the substance.
5. Detect artificially shifting of the substantial amount of income to advantageous environments having taxation benefits by means of automatic exchange of information between the tax authorities.
6. Recognizing location of the groups where they can enjoy tax incentives.
1. Location of IPR and place of conceptualization and development of IPR.
2. Legal ownership or beneficiary ownership of intangibles and related payment.
3. Requires providing an overview of MNE’s global chain.
4. Identify whether the revenue and profit generated from all jurisdictions are proportionate with the substance.
5. Detect artificially shifting of the substantial amount of income to advantageous environments having taxation benefits by means of automatic exchange of information between the tax authorities.
6. Recognizing location of the groups where they can enjoy tax incentives.
What are the documentation requirement for each MNEs conducting interstate transactions with their group companies
1. Master file to provide MNEs blueprint.
2. Local file to provide material TP positions of the local entity with its forign affiliates.
3. CBC reporting to provide jurisdiction wise information.
2. Local file to provide material TP positions of the local entity with its forign affiliates.
3. CBC reporting to provide jurisdiction wise information.
What are the key services provided by BIATConsultant ?
1. We conduct training which will involve knowledge sharing sessions to increase the awareness of three tire documentation requirements, its structure and compliance requirements.
2. Prepare diagnostic review to assist in preparing TO compliance obligation.
3. To analyze the intangible on the basis of BEPS guidance to ensure that the group members are contributing towards enhancement, development, maintenance, protection, and exploitation of intangibles and being remunerated appropriately.
4. To develop processes and procedures for compliance and train the group members to meet documentation deadlines to ensure the alignment between the local and global documentation.
2. Prepare diagnostic review to assist in preparing TO compliance obligation.
3. To analyze the intangible on the basis of BEPS guidance to ensure that the group members are contributing towards enhancement, development, maintenance, protection, and exploitation of intangibles and being remunerated appropriately.
4. To develop processes and procedures for compliance and train the group members to meet documentation deadlines to ensure the alignment between the local and global documentation.
