Value Added Tax (VAT)
VAT is also an area strongly impacted by the BEPS action plan which key measure, the SAF-T (Standard Audit File for Tax), objective is to implement electronic access, in an unified format (XML), to the VAT authorities which are closely monitoring VAT transactions by performing joint VAT audits in the EU.
Before the Blockchain comes in the picture, companies will have to (or have to) provide not only detailed VAT ledgers, but complete general ledgers (such as the FEC - Fichier des écritures comptables - in France), master data, sales ledgers, purchase ledgers, etc. Penalties will be charged for the companies which do not comply.
Solutions for the companies are to update ERPs, which can be costly, implement integrated applications and enhance supply and distribution flows.
Is your company ready for the eras of digital and near live reporting for VAT? Do not hesitate to contact us.
International Tax Structure
There are a lot of challenges in the world of Corporate Tax for the years ahead.
BEPS, Brexit, GOP Tax reform and digitalization of tax are some of the hot topics.
One of the coming changes is the switch from commissionaire distribution models to limited risk distributors. The former commissionaire models are no more a sustainable option (due to increased risk of permanent establishment) under the OECD BEPS Project.
In addition, Corporate Tax Strategy and the Transfer Pricing practices have to be aligned.
To find out what Corporate Tax reforms can impact your tax structure, do not hesitate to contact us.
Headquarters implementation in Switzerland
Tax rulings, set-up of subsidiaries in APAC, EMEA, LATAM and US regions.
Representation before the authorities, request of ruling and support during tax audits.
The OECD BEPS project has been a significant game changer on how Transfer Pricing methods are choosen and applied. We often here finance professionals saying “we have a Cost +5 method”. Well this is not a method. It should be the result of a study carried with the appropriate due diligence.
Nowadays the Corporate Tax Strategy and the Transfer Pricing practices have to be aligned and well documented.
These practices are under unprecedented scrutiny by the local government authorities and one solution cannot be transposed across all the countries where you operate.
Permanent establishments (despite double taxation agreements) and tangibles valuation are increasing risks factors for companies.
For companies it is time to evaluate, address, align and adjust the transfer pricing methods. Are you ready?
Transfer pricing best practices studies, review of intra-group transactions, funding strategies.
Creation of BEPS mandatory documentation, implementaiton of country-by-country reporting.