FS Transfer Pricing Decoded

This episode focuses on the real estate sector and we hear from Bill (US), Ronny (Germany), Omar (the Netherlands) and Peter (UK) regarding their experience of some of the transfer pricing issues that arise within that sector.

Following on from Episode 9, Part 1 on general transfer pricing considerations relevant to financial transactions , Part 2 of this series covers specific transfer pricing considerations relevant to the banking sector, including interactions with a bank's Funds Transfer Pricing (“FTP”) mechanism.

Episode 9 (Part 1) sets the scene by discussing some important transfer pricing considerations relevant to financial transactions within multinational groups in the context of the final OECD Guidance on Financial Transactions released in 2020.

Cost allocations are a challenge for many multinationals, creating issues which extend far beyond tax and transfer pricing. In this podcast the speakers discuss these challenges covering controversy, governance and operational implementation.

This episode, recorded in Summer 2021, discusses factors in the asset management sector which have had an impact on operating models (including regulation, market environment and technology) and the associated transfer pricing considerations.

The world is changing and so are the banks – what are the implications? This episode of the series focusses on emerging trends in the banking sector and some potential implications on transfer pricing models. In this episode Rasmus, Willy, Pris and Francesco discuss emerging trends in the banking sector across Europe and AsiaPac. Listen in to hear latest trends from Deloitte UK's risk advisory team and how this translates into transfer pricing considerations. 

Technology in the insurance industry could be in a variety of forms including apps, telematics, digital distribution models and automated underwriting and claims underwriting systems. In this episode, the speakers discuss how transfer pricing models may change as a result of the shift towards the technology across the value and how data could be treated from a transfer pricing perspective. 

In this episode, hear about common transfer pricing challenges faced by providers and recipients of intercompany services, transfer pricing controversy related to India and lastly charging for the use of financial services brands and some of the challenges seen which have been raised by tax authorities of both the licensee and licensor. Speakers include Darrin Litsky from Deloitte US (previously at the Internal Revenue Service), Andrew Skipsey from Deloitte UK (previously at HM Revenue & Customs) and Anis Chakravarty from Deloitte India.

This episode explores the use of technology within FS organisations where this is a key value driver in the business model. This episode also goes into some of the possible key transfer pricing considerations commonly associated with technology-related intangibles. In this episode, hear from Sam, Inna, Jeremy and Mei; where they discuss the interaction between tax and technology in the FS sector.

The second episode of the series focusses on post-Brexit transfer pricing considerations in the Financial Services sector. In this episode hear from speakers in the UK, France, Germany and Ireland as they discuss post-Brexit Transfer Pricing models and their thoughts on recent EU regulatory developments and what these could mean from a transfer pricing perspective.

The first episode of the series discusses a topic which many organisations are increasingly having to assess and manage from a tax perspective – staff working from outside of their country of employment.  So when can such movement of staff create a permanent establishment (PE) for corporate tax purposes and what are some of the key personal tax consequences to think about? In this episode listen to Stephen, Louise, Giles and Murray; where they discuss these points through case studies. Case study questions: Example 1: A middle office employee, employed by a French entity, is forced to work remotely in the UK. - What are the basic PE principles and personal tax consequences to consider? - What changes if they now choose to work in the UK? - Would it matter if their employer gave them a home work contract and for a longer period? - What if colleagues from other departments were working from home in the same country? Example 2: A sales person works remotely in their home before relocating to the country of their new employer. - What are the PE considerations in this example? - What happens if they adopt a split working model working in both countries? Profit Attribution – if transfer pricing principles are followed, can the PE considerations be ignored?