As a result of the OECD’s BEPS Action Plan, MNEs are experiencing increased exposure to tax controversies if they are not simultaneously in control of their Operating and Transfer Pricing models. The lack of simultaneous control and visibility may lead to misalignments between the information being communicated in the Transfer Pricing and Country by Country reports, and Corporate Income Tax returns. This in turn prompts tax authorities to challenge the corporation’s tax structure as a result of lack of coherence and substance.

Through conducting a Value Chain Analysis (VCA), the potential mismatches in where the people functions are located, where the value is created and where the profit is landing can be identified. Due to the increasing risks attached to traditional tax strategies, it is essential that Tax and Transfer Pricing Professionals adopt a more proactive approach on value chain analytics to avoid potential tax controversies.

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