Loyens & Loeff

Documentation

To make sure that your documentation is in order, it is important to work with professionals. However, you also want to make sure that this work is both compact and cost-effective. Together we will work hand-in-hand to produce tailor-made (local or global) transfer pricing documentation that reflects your aims. This includes local files, master files and Country-by-Country reporting, as well as other documentation, such as intercompany agreements.

Profit split method
Historically, the profit split method has generally only been used in exceptional cases, where the TNMM was clearly not appropriate. However, with the arrival of the new OECD guidance on the use of profit splits and its follow-up guidance due in 2016, the use of the profit split method is expected to increase substantially.

Do you want to know whether the profit split method is the most appropriate approach for a particular situation? And do you want to determine the most appropriate way to split your company’s profits, in-line with the OECD’s guidance on the use of the profit split method in integrated supply chains?

To make your options clear, Loyens & Loeff can help you develop tailor-made solutions, putting you in control to determine which decisions are best for your company. We work effectively to resolve these issues. We help you to avoid discussions with the tax authorities on whether to use the profit split method, to avoid double taxation on your business profits on a sustainable BEPS-proof basis, to obtain unilateral and bilateral APAs on the application of the profit split method and we make sure that these are based on a sustainable transfer pricing system, for integrated supply chains and intellectual property structures.

Documentation & CBCR
Transfer pricing documentation contains many different requirements. Meeting these requirements lowers the risk of audit, prepares multinationals for discussions and mitigates the risk of double taxation.

As a multinational company, aligning your documentation with these requirements forms a particular challenge. Requirements include having to have a master file, local files for specific countries, that contain more detailed information, and Country-by-Country reports, comprising of an annual report for each of the tax jurisdictions where you operate.

With advice and support, we enable you to bring your documentation in-line with these requirements. Together we can develop a pragmatic action plan enabling this to happen, making your documentation up-to-date in the most efficient way. Action plans consist of: setting up a Country-by-Country team; carrying out the data collection; analysing the outcomes; and providing a Country-by-Country report. We do this using a tailor-made approach that provides you with a number of different possibilities for achieving your documentation goals, in a way that fits in with your company.