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January 13, 2022
2022-5053

Thursday, 27 January 2022 | BorderCrossings . . .With EY transfer pricing and tax professionals (1 pm ET)

Re-examining the “aggregation principle” in transfer pricing and reviewing latest OECD developments

Multinational companies often encounter related transactions – for example, the sale of tangible goods with the use of intangibles, or the sale of goods along with services being provided. These related transactions often raise questions about when it is appropriate to aggregate related transactions versus separately delineate and evaluate them. Other questions may center around the considerations and implications for either treatment.

This month’s BorderCrossings webcast, a follow-up to our August BorderCrossings webcast on the “realistic alternatives” principle, addresses these issues by focusing on the related “aggregation principle” in transfer pricing. The panel will explore the evolution of this principle through court cases and regulatory changes to its codification in the Tax Cuts and Jobs Act and recent guidance from the Organisation for Economic Co-operation and Development (OECD). We will also evaluate guidance in US regulations and OECD transfer pricing guidelines, and how they apply, through examples.

The webcast will also include a brief update on recent activities around the OECD’s “Pillar One” and “Pillar Two” initiatives under BEPS 2.0.

We hope you will be able to join us for this important webcast.

Date: Thursday, 27 January 2022

Time: 1:00–2:15 p.m. ET New York/Toronto; 10:00–11:15 a.m. PT Los Angeles/Vancouver

Registration: Register for this event.

Panelists

  • Helena Aten, Senior Manager, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP
  • Dipan Ghosh, Senior Manager, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP

Moderator

  • Mike McDonald, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objective: Identify the history of the aggregation principle as it has evolved from regulations, OECD guidance and US case law into statutory law and US tax treaties. This intermediate-level, internet-based group course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

Learn about and register for Thought Center webcasts

You can learn about and register for any Thought Center webcast here.

 
 

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