Michaela Merz


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TP – The OECD released a final paper on Financial Transactions Transfer Pricing


The OECD published a new chapter of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Authorities (“the OECD Guidelines”). The new chapter provides guidance on the transfer pricing for loans, guarantees, cash pools, hedging and captive insurance transactions.

The new chapter is the first OECD guidance on transfer pricing for financial transactions issued in final form and will be the main reference point for pricing and auditing related party financial transactions in most countries going forwards.

Loan, guarantee and cash pool policies that Swiss groups apply across their international operations should be reviewed and updated to ensure compliance with the new guidance.

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EU Commission – Possible VAT implications of Transfer Pricing


I would like to share with you the paper with the opinion of the EU Commission VAT Expert Group issued on 18 April 2018 on possible VAT implications of Transfer Pricing.
The paper contains also interesting examples which could be of interest for you. Continue reading


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Webinar: Resolve the dilemma between customs valuation and transfer pricing


Determining the customs value of goods is a challenge at the best of times – and even more so in the wake of a recent European Court of Justice decision jeopardising the practice of determining customs values on the basis of transfer prices. We have decided to hold a free webinar to help you tackle the inherent conflict. Continue reading


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EU – TP adjustments and custom value – The impact of Hamamatsu Photonica Deutschland GmbH (C-529/16) under the Union Customs Code and what does it mean in detail


The Hamamatsu case, in essence concerns the question whether, in order to establish the customs value, it is allowed to use an agreed transaction value (with Customs), which consists of the amount (price) initially invoiced and declared at import, Continue reading


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Poland – Brief summary of recent tax situation


Based on the latest World Bank’s “Doing Business” report Polish tax system is one of the most complicated and complex systems within the EU. In general, significant time investment is needed to fulfill tax obligations in Poland.

Polish legal provisions are often not formulated in clear way. Continue reading


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OECD: Possible VAT implications of Transfer Pricing


The Commission services wish to discuss with the VAT Committee the possible VAT implications of transfer pricing rules laid down for the purposes of direct taxation. Such rules are aimed at ensuring that the conditions of the transactions within a multinational enterprise group (“MNE group”), including the price, match comparable market conditions and that profits are fairly divided between the jurisdictions in which a multinational enterprise (“MNE”) operates1. Continue reading


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Transfer Pricing Perspectives


tp-perspectives-social-media-tile-1Transfer pricing is a leading risk management issue for global businesses but probably equally a source of opportunities to “set things right”.
Explore PwC’s Transfer Pricing Perspectives for more HERE.