BANSBACH has acquired strong partners in the growth region of Lake Constance, with Dr. Altmann in Überlingen, the tax consultancy firm Böttinger in Frickingen-Altheim and Bodensee Treuhand GmbH Wirtschaftsprüfungsgesellschaft, effective 1 January 2023.
With a total of 35 colleagues, WP/StB Dr. Michael Altmann and WP/StB Wendelin J. Böttinger will manage their respective locations and, together with StB Olaf Gläser, will be responsible for the development of the Lake Constance region. Bodensee Treuhand will provide auditing services alongside BANSBACH GmbH. This merger enables BANSBACH to offer its comprehensive advisory services in the Lake Constance area, with continuity through regular contacts and personnel. Services include bookkeeping, preparation, and auditing of annual financial statements, accounting and audit-related consulting services, national and international tax and legal consulting, transaction services, and business consulting services for CFOs.
For more information on the ongoing BANSBACH growth and doing business in Germany, click here.
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Kreston Global welcomes new member firm in Uganda
January 4, 2023
Kreston Global has welcomed a new member firm in Uganda to the network.
Kreston HM (formerly Nexia HMS ) focuses on providing audit, accounting services, and tax advisory and was founded by managing partner Hitesh Mehta, in 2005. Based in Kampala, with another office in Jinja, the firm has 3 partners and 45 staff and has rebranded as Kreston HM to take advantage of the extensive global reach of the Kreston network.
Hitesh Mehta, Managing Partner at Kreston HM, said:
“We are very pleased to be joining the Kreston network and becoming part of its highly-active African region, as well as an extensive international network. We are looking forward to becoming Kreston HM and are excited about the future.”
“Kreston is delighted to welcome Kreston HM to the network to drive the continued growth of our Africa region. They are one of many new firms joining the network and extending our worldwide footprint. We look forward to helping them connect with our members across the network as they explore new opportunities both at home and globally.”
News
BANSBACH Improved in Employer Ranking Index
December 23, 2022
Congratulations to Kreston firm BANSBACH who round off a successful 2022 by significantly improving their ranking in JUVE‘s Top Tax Employers 2023, moving up eight places to 14th in the country.
This is largely a result of employee workplace innovations such as part-time partnerships and the option to work from home, but also a significant strategic expansion plan. This has seen BANSBACH adding a number of acquisitions and strategic partnerships with firms like O&R Oppenhoff & Rädler in Munich as well as adding an entire team from BDO in Freiburg.
Ankur Jain named new Middle East Indirect Tax Director
December 19, 2022
Kreston’s Global Indirect Tax Group has welcomed a new regional director. Ankur Jain leads the indirect tax practice at MMJS, part of Kreston Menon, our member firm in the UAE.
In accepting the role Ankur Jain said:
“It is an honour to be appointed as the Middle East regional director of the Global Indirect Tax Group (GITG), particularly when Indirect Tax was introduced in many countries in the Middle East. In this fast and ever-changing tax landscape in the region, this opportunity brings a unique opportunity for me to share knowledge, build partnerships, work on referrals, and ultimately add value to our clients and Global Indirect Tax Group (GITG).”
News
Business failure and challenging antecedent transactions
September 29, 2022
If you have lent money to a business that has become insolvent, then recovering your debt can be a difficult process. In many cases, the best course of action is to investigate the root cause of the business’ failure to develop a greater understanding of who’s liable. Under scrutiny, you may even discover that actions took place before insolvency that put your money at risk. If any antecedent transactions did take place, then you need to challenge them in order to recover your assets.
Our advisers are deeply experienced in identifying root causes and contributing factors of business failures. They’ll help you find out if your credit was put at risk unnecessarily and guide you through the most appropriate course of action to recover what’s owed to you. If this is something you’d like to learn more about, get in touch and we’ll discuss how we can help you.
The scope of our business failure investigation services?
We have many forensic accounting specialists in our network, who can use their experience to investigate the circumstances surrounding the failure of a business and determine if any wrongdoing took place. Working closely with legal advisors, they’re ready to do what is necessary to give you closure on your losses following a business failure, including:
Tracing funds, identifying and recovering assets, and conducting due diligence reviews
Uncovering any wrongdoing that took place leading up to insolvency
Providing evidence and explaining the nature of the wrongdoing in court
Investigating antecedent transactions
It could be that antecedent transactions took place in the two years prior to insolvency. In such cases, we work with multi-disciplinary teams including legal advisers and forensic experts to bring claims against the responsible parties. Our team of experts are experienced in uncovering and challenging the many types of antecedent transaction, including but not limited to the following.
Misfeasance: If a director has breached their duty by acting outside of the company’s best interests, damaging your returns in the process, then as a creditor you have the right to make a claim against them.
Preferential transactions: If the company made a transaction with another creditor, which gave them a preferential outcome after the insolvency, their gain may have been your loss. We can help you demonstrate that preferential transactions have taken place and work to convince the court that a reversal should be put in place.
Wrongful trading: If the director continued trading after it was clear that the company would become insolvent, then the court could declare them personally liable. We can use our expertise to help you prove that this was the case and improve your chances of recovering your debts in the process.
Why choose Kreston Global?
Don’t allow wrongful behaviour to go unchallenged. Kreston Global’s team of forensic accountancy specialists is on hand to help you. We will leverage our expertise and connections to obtain disclosures, trace and recover assets, and make claims against those responsible wherever we find misconduct.
You can look forward to many benefits when you become a member. Namely, access to an international network spanning more than 115 countries and 160 accountancy firms, each of whom adheres to the accountancy standards of their respective nation. We are also knowledgeable on international standards, meaning that we are able to pursue your business failure investigation wherever it may take us.
If you would like more details about our services – whether related to business failure investigations and antecedent transactions or otherwise – get in touch with us today.
News
Investors face Cryptocurrency challenges
June 28, 2022
Since the arrival of Crypto assets and ever-growing technology, investors face Cryptocurrency challenges as it has become much more dangerous with the lack of regulations and laws in place to reduce scams and crypto crime. Kreston Global member Ganesh Ramaswamy of K Rangamani and Associates LLP explains the impact this has had on Asia in Financial Regulation International.
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How the Ukrainian accountancy market is responding to the war
June 27, 2022
Sergey Atamas, managing partner of Kreston Ukraine, explains how Ukrainian accountants and auditors are dealing with the ramifications of the war. Read the full article here.
News
Crackdown on digital art
June 1, 2022
Surandar Jesrani of UAE member firm Kreston Menon (MMJS Consulting) writes about international regulator moves to crack down on digital art assets in Accounting and Business news. Read the full article here.
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Kreston Reeves appoints restructuring partner
May 27, 2022
Accountants, business and financial advisers Kreston Reeves has strengthened its market-leading Restructuring team with the appointment of Carrie James.
A licensed insolvency practitioner, Carrie joined Kreston Reeves on 18 May from SKSi where she was the managing director and head of insolvency.
She brings to the firm an impressive track record of helping businesses solve problems that are too great to be resolved on their own. Much of her work has an international perspective, with strengths in the mining and natural resources sectors. Carrie also brings a proven track record in building and growing a business, founding SA Insolvency before merging with Benedict MacKenzie, now SKSi, and leading its expansion programme.
Carrie is the immediate past president of the Insolvency Practitioners Association and sits on its External Affairs and Membership Committee and its Management and Risk Committee.
Commenting on her appointment, Carrie said:
“Kreston Reeves is a firm I have long admired. It has a strong position in London and the South East yet with significant opportunity for growth. Importantly, the firm is principled with values that reflect my own. it is an exciting time to be joining the firm.”
Andrew Tate, Partner and Head of Restructuring and Transformation at Kreston Reeves said:
“This is a significant appointment for Kreston Reeves. Carrie is highly respected and with a strong presence in the insolvency community. We are thrilled by her decision to join Kreston Reeves and look forward to working alongside her.”
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Kreston Global welcomes North Macedonian member firm
May 13, 2022
Kreston Global has today welcomed Kreston Macedonia, based in North Macedonia, to its global network.
Kreston Macedonia was founded earlier this year and was originally known as TPM Audit prior to joining the Kreston Global network. Led by founding partner Nenad Tortevski, it provides audit, tax, accounting, and valuation/forensics services to businesses operating in North Macedonia, from its Skopje office. They have launched a new website under their new name, which can be found here.
Liza Robbins, Chief Executive of Kreston Global, said:
“It is with great pleasure that I welcome Kreston Macedonia to the Kreston Global network. We are experiencing an unprecedented level of growth, a tribute to the exciting work carried out across the network in recent months and years. We will be working with our newest colleagues to build their links across the network as they explore new opportunities both at home and abroad.”
Nenad Tortevski, Founding Partner at Kreston Macedonia, said:
“Kreston Global are unique amongst global networks, in combining an established brand with an ethos of dynamism as well as market-leading services. They were a natural partner for us as we embark on this exciting venture.”
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Business planning
May 6, 2022
When starting a new business or scaling up an existing one it is essential to invest time and consideration in constructing a robust business plan. The benefits of business planning are endless and ever evolving. With a clear roadmap for your organisation, you will be able to anticipate potential problems and have a greater understanding of how to solve them. You’ll also have improved clarity and focus on your goals, providing greater confidence in your decision-making.
So, how can we help? With over 50 years of experience, we’ve helped businesses grow into new markets and reach global success with our business planning services. Our advisors have the tools and the know-how to elevate your business to where it wants to be. We use efficacious planning strategies to create bespoke pathways for your business, realising future goals and positioning for growth. Get in touch with a member of our team today to find out more.
Our business plan consulting services
At Kreston Global our custom business plan writing services adapt to our clients ambitions, supporting growth into new markets, expanding operations abroad and realising your company’s goals. With decades of experience combined with a breadth of specialties spanning across the globe, the Kreston Global family are poised to help your business seize opportunity and forge into new territories with effective business planning.
What should a business plan include?
Each business plan will be unique to the needs of the organisation creating it, however these core facets tend to be a good starting point when building a business plan. Consider this plan as a framework from which your company will
An assessment of the market, competitors and customers
In-depth market research is essential for goal setting and understanding the impact of your products and services. The Kreston Global research network provides our member firms with the most immediate and relevant market data with which to advise our dynamic clients.
Set objectives for an upcoming period
Creating a list of goals and ideals for your business in the future can help your team to attain them and provide direction for the year ahead. Kreston Global advisors can help your company identify goals with equal ambition and attainability.
Set Key Performance Indicators (KPIs)
Understanding achievement and attainment is only possible when clearly defining what ‘success’ is for your business. Clearly defining KPIs for your company can give your team a vision and help provide direction towards new goals.
Expected challenges the business will face
Through understanding the market and the upcoming challenges to your organisation, a business plan can account for harder periods for your business, offering options for financial conservation and alternative cash flow solutions during challenging seasons.
Operational changes and workforce information
Mapping out expected and upcoming changes for your business can be helpful to assist managing transitions and setting expectations for change outcomes.
Financial forecasts and any upcoming investments.
Giving a clear overview of the expected financial year for your business, as well as accounting for upcoming expenditure will allow your company and other stakeholders to understand expected cash flow as well as identify any potential shortfalls.
A business mission statement
Establishing your business vision and an ethos can be essential for meeting future goals and steering the direction of your company’s development. Setting expectations of your workforce and of the impact that you want your services or products to provide can bring clarity to a business mission.
When should an organisation write a business plan?
There really is no ‘wrong’ time to write a business plan, but sadly many companies neglect essential strategic planning as a result of the demands of day to day operations.
Some of the most important stages for your company to have a strong business plan is if you are:
Starting a business
Looking to expand into new locations
Expanding product and service provision
Working through financial or structural change
Business planning for international expansion
When conducting business planning for growth, especially when looking to expand your business globally, it can be vital to bring in international accounting experts. At Kreston Global our world-wide network of professionals consistently excel in providing our clients pathways for growing into new markets and jurisdictions.
What are Kreston Global’s compliance standards for business planning?
Kreston Global partner firms closely observe the professional standards of their respective countries as well as following strict international regulations.
As a global network, we employ an effective internal monitoring programme, ensuring that all our members meet the International Standards on Quality Control and the International Standards on Auditing for the conduct of transnational audits. Every Kreston partner firm follows the code of ethics as dictated by the IESBA (International Ethics Standards Board for Accountants).
As a committed member of the Forum of Firms, an association of international networks of accounting firms, Kreston Global is dedicated to meeting high-quality standards in financial reporting and auditing practices across our international community.
Wherever you are in the world, wherever your business operates, you can trust that our standards will be universally and consistently met.
Why choose Kreston Global for custom business plan writing services?
We operate across 110 countries and have 27,500 professionals in our global network. When you become a member, you’ll gain access to all our professionals’ information and expertise. We aim to build trust and confidence in the short and long-term goals of your business, with our clear and comprehensive business planning services.
Our business plan writing services cover UK-based or international businesses, adapting to suit the size and ambition of your company. Get in touch with one of our business planning experts today and take your business to new heights.
Contact Kreston Global to find out how we can support your business with business planning services
Want to know more about our business planning services? Get in touch
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GAAP financial statements
Local Generally Accepted Accounting Principles (GAAP) refer to the rules that are required to be followed in a specific country when filing financial statements. GAAP must legally be done by any publicly traded and regulated business. Without it, ramifications may come into play.
This method of reporting financial statements is done all over the world in accordance with local GAAP accounting rules. This ensures that a business’ finances are visible, consistent and comparable. When this is done, business owners and investors can see the overall health of a company.
Our GAAP financial statement services
At Kreston Global, our international network of accounting professionals each excel in complying to their local financial reporting requirements through GAAP. We ensure that your business is able to meet the reporting standards of all the jurisdictions it operates within, keeping all bases covered with our cross-national consultants. Our partner firms have access to some of the best market research, deepening our understanding of a variety of sectors, ensuring that our financial reporting services meet the full needs of each client, identifying areas of improved efficiency and opportunities for growth.
What are GAAP financial statements?
GAAP stands for Generally Accepted Accounting Principles. These principles differ in each jurisdiction, meaning that it can be valuable for your business to consult an expert in the accounting regulations of your operating country. By adhering to GAAP regulations within financial reporting, you can ensure that your business is operating at a high standard of compliance and that your financial reporting is understandable and comparable for stakeholders and investors. By producing high quality and comprehensive financial reporting, businesses can better understand their strengths and weaknesses, communicate better with stakeholders and craft better informed business plans for growth.
Format for GAAP-compliant financial statements
When preparing financial statements in accordance with local GAAP, there are key requirements that must be observed for compliance. Whilst the specifics can vary from country to country, some elements remain consistent throughout. These are the five main principles of any GAAP reporting:
A statement of financial position at the end of the period
This statement includes a summary of financial balances within the business. At the end of a period, the business will show the assets, liabilities and equity of its operations. When this is done, the overall financial position of the business can be understood.
A statement of comprehensive income for the period
The second required financial statement under GAAP is a statement of comprehensive income. This highlights the income of a company whilst displaying expenses too. With this information, the net income for a specific period is visible.
A statement of changes in equity for the period
Local GAAP financial statements will also include changes made to the equity stakes in a business. This will summarise the transactions related to shareholders over a specific period.
A statement of cash flows for the period
Across the period, cash will flow in and out of the business. This is highlighted in this section and shows whether all the revenues on the income statement have been collected.
Notes containing a summary of significant accounting policies and other explanatory information
This final section will be found in the footnotes of your financial statement reporting. It will include additional information on the above statements and the policies your firm follows. This section provides context for your financial reporting and can be important for stakeholders to understand your company’s financial health.
Separate vs consolidated GAAP financial statements
When it comes to your reporting, there are two options available:
The first is consolidated financial statements in accordance with GAAP which refers to the reporting of the finances of two or more companies at the same time. This is done if a parent company has several subsidiaries and stakeholders want to see how the overall health of the company appears.
The second option is separate local GAAP reporting which is the financial reporting of just one business, be that the parent company or a subsidiary. This can be useful when an investor is looking to become a stakeholder in an individual business.
What is the difference between GAAP and IFRS financial statements?
Whilst GAAP reporting is localised and dictated by the country in which your business operates, IFRS (International Financial Reporting Standards) are requirements that are internationally recognised and essential for financial reporting to be comparable globally. Both GAAP and IFRS standards must be met within financial statements. Our accounting consultants provide expert advice in both IFRS and GAAP compliance and can support your organisation through all of its financial reporting needs.
What are Kreston Global’s compliance standards for GAAP financial statements?
Kreston Global partner firms comply with the high professional standards of their respective countries as well as adhering to international regulations. Our understanding of local compliance and regulatory standards allow us to provide exceptional GAAP financial statement consultation across the globe.
As a world-wide organisation we employ an broad internal monitoring programme ensuring that all our members meet the International Standards on Quality Control as well as the International Standards on Auditing for the conduct of transnational audits. All Kreston partner firms follow the code of ethics as dictated by the IESBA (International Ethics Standards Board for Accountants).
As a proud member of the Forum of Firms, an association of international networks of accounting firms, Kreston Global is committed to meeting high standards in financial reporting and auditing practices across our worldwide community.
Wherever you are in the world, wherever your business operates, you can trust our standards to be universally met and exacting.
Why choose Kreston Global for GAAP financial statement services?
Here at Kreston Global, we’ve gained over 50 years of expertise in accounting and finance. This means we know a lot about local GAAP accounting and the challenges that come with it. Fortunately, our network of professionals around the world has the solutions to your problems. If you want to join this network of 25,000 people, become a member.
Contact Kreston Global to find out how we can support your business with GAAP financial statement services
Want to know more about our GAAP financial statement services? Get in touch
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US GAAP financial statements
The American Generally Accepted Accounting Principles (US GAAP) are widely followed accounting rules and standards used in financial reporting. US GAAP is used to ensure that every organisation’s financial statements are consistent and transparent.
These financial statements are prepared on a monthly or annual basis and are a basic requirement for all businesses to complete. This is done whenever your business’s management or board of directors choose to do it.
So, when the time comes to get your affairs in order, you’ll want to know the best practices for US GAAP-compliant financial statements in both presentation and disclosure. That’s where we come in. With 50 years of experience in advising leading companies, we provide solutions to common problems in finance and accounting. Get in touch with a member of our team to find out more.
Elements of US GAAP consolidated financial statements
When illustrating your financial statements in compliance with US GAAP, you will follow the same steps as IFRS. Without the correct information included, your business may be penalised. Ensure the following points are included:
A statement of financial position at the end of the period
Sometimes known as a balance sheet, this statement represents the assets, liabilities and equity of a business. The information reveals the overall value of a company.
A statement of comprehensive income for the period
This highlights the profit or loss for the period. This statement will include all items of income and all expenses to show the net income for a specific period.
A statement of changes in equity for the period
Any changes made to the equity of each stakeholder will be included in this section. This information will include total share capital, retain earnings and dividend payments.
A statement of cash flows for the period
Used as a summary of the movement of cash flow in and out of a business. This measures how well a business manages its cash and is a key indicator of its debt repayment potential.
Notes containing a summary of significant accounting policies and other explanatory information
If any extra information is required to support the statements above, this will be the opportunity to do so. You will also state the accounting policies that you have followed.
Why choose Kreston Global as your US GAAP financial statements solution?
Formed over 50 years ago, we have experts in 110 countries around the world. This means we can tackle issues on a global scale while remaining true to our founders’ values of providing responsive, empathetic and personal support. This is for both mid-sized entrepreneurial businesses and individuals looking to expand overseas.
So, whether it’s private equity illustrative US GAAP financial statements or carve-out financial statements, our team can help. We have the experience and determination to drive positive results for your business.
Theo is a non-executive board member of the Cyprus Securities and Exchange Commission (CySEC), and leads the Audit Committee of CySEC. In 2018, he was appointed as the Finance Director of one of the biggest football clubs in Cyprus, Anorthosis Famagusta (Football) Public Limited.
Theo’s portfolio covers M&A due diligence, investment appraisals, forensic audit, internal audit and risk management advice, as well as corporate governance best practice.
Introduction into family offices
April 22, 2022
What is a family office? “Family offices are typically viewed as being somewhat of an enigma” – Preqin Family Offices Survey 2010.
Although the concept of a family office has been in place for centuries, the modern understanding of a family office can be attributed to JP Morgan and JD Rockefeller.
While each family office is considered to be unique (in their source/category, size, structure, strategy), they do share many qualities with respect to working practices;
The notion of a family office is attributed to any group of professionals (who can be legal, tax, investment, concierge, estate planning, charitable giving advice, etc) who provide professional and/or personal dedicated services to a family.
Family office characteristics
One can categorise family offices in
1. Single-family offices (traditional family office) (SFO)
Citi private bank and Union bank place the number of single-family offices around the world to an estimated 10,000 (with about 6,000 in the US according to Deloitte) who serve families with more than 200m USD.
2. Multifamily offices (MFO)
These perform most functions of a single-family office serving a limited number of families (usually for assets more than 20m)
3. Outsourced family office
This is basically a cooperation of the different professionals (ie: legal, tax, investment etc) who are not under the same roof/structure
There is no specific structure/model used for family offices with various options being used:
· Private family trust companies
· Family investment companies
· Investment funds
· Foundations
· Holding companies limited by guarantee
Benefits of a family office compared to other models
Family offices, going from outsourced to MFO, to SFO have increased benefits on each step-up.
It is built around the family’s needs whatever they may be (hence the uniqueness of each family office)
It provides a dedicated team of highly skilled professionals who have the time to obtain a deeper understanding of the family’s needs, risk tolerance and other investment principles of the family’s wealth.
Confidential and private information is only shared by a small group of individuals who work for the company.
There is more control of the assets and investments making it easier to limit risk exposure in all aspects (tax/legal/financial etc)
It provides the owners with time to carry on with their daily lives knowing that all their affairs (personal, family wealth, family succession and others) are handled by this specialised group of people.
Family office jurisdiction considerations
Due to its perpetuity, a family office (MFO/SFO) is never actually a single office or building and may span more than one country depending on the needs of the family.
The main office selection is a complex and challenging exercise taking into account factors such as availability of a skilled workforce and professional services, regulatory and tax framework, political stability, immigration rules and cultural aspects amongst others.
Cyprus as an ideal location for a family office
Cyprus ticks all the aforementioned “consideration” boxes that a family needs to take into account before taking the next step in their family planning.
As an EU member, Cyprus follows EU directives and OECD guidance and has a wide range of Double tax Treaty Network as well as numerous corporate and individual tax incentives, with its legal and tax system modelled on the English and common law system.
Having the 2nd highest tertiary educational attainment rate in the EU makes it very easy to find highly skilled professionals both in terms of management and attaining high-quality professional services.
How we can help
At Kreston Ioannou & Theodoulou we understand that family offices must be designed based on the specific needs, circumstances and concerns of the families they serve.
Our multidisciplinary team can assist in the design of the structure that fits the specific family needs and provide ongoing support to the family office for example for asset protection, succession planning, family governance, tax planning and more. Our team is here to help you.
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David Whitmer
National Transfer Pricing Lead, CBIZ and Transfer Pricing Lead, Kreston Global
David Whitmer has more than 20 years of experience in transfer pricing consulting services, primarily with large international accounting firms, covering transfer pricing planning, intellectual property valuation, financial modelling, and transfer-pricing disputes in a number of industries, including finance, chemicals, pharmaceuticals, software, manufacturing, services and tax-exempt organizations.
Transfer Pricing FAQs
What is transfer pricing?
In simple terms, transfer pricing is the process of setting the prices charged between associated enterprises in cross-border transactions, which can involve transfers of tangible goods, services, and intangible property, as well as financing transactions.
When a cross border transaction occurs between associated enterprises, tax administrations in the respective countries are especially interested to ensure that the taxable profits of multi-national enterprises (“MNEs”) are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country yield results that are consistent with the economic activity undertaken and the results that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances.
What are the rules?
Each country has different transfer pricing rules, so it is important to speak to a country tax specialist to make sure you are following local country requirements. With only a few exceptions, most countries’ transfer pricing rules are based on the “arms-length” principle, where pricing between associated enterprises should reflect the prices that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances
The OECD has also published transfer pricing guidelines (“OECD Guidelines”) here for member countries and cooperating non-member countries to follow. Most countries’ transfer pricing rules are based on the OECD Guidelines, though there may be certain differences in interpretation, application, and administration among countries.
If the transfer price is not arm’s length, the tax administrator has the authority under the tax jurisdiction regulations to make adjustments by reallocating items of gross income, deductions, credits, or allowances in order to properly reflect income between the entities.
What is an example of transfer pricing?
The following case illustrates various examples of transfer pricing related issues:
A MNE group, ValveCo, is in the business of designing, producing, and selling valves. ParentCo is responsible for design, manufacture, and distribution in its territory. SubCo1 operates as a licensed producer in its jurisdiction (Transaction 1). SubCo1 performs certain development work under the direction of ParentCo (Transaction 2). SubCo1 purchases components from ParentCo to be used in its manufacturing process (Transaction 3). SubCo1 relies on ParentCo for certain management and administrative functions (Transaction 4), as well as funding of its operations (Transaction 5). SubCo2 purchases products from ParentCo and SubCo1 for resale to third-party customers in its jurisdiction (Transaction 6).
Who do the transfer pricing rules apply to?
The transfer pricing rules are relevant to MNEs with controlled transactions among associated enterprises in different tax jurisdictions. Uncontrolled transactions do not fall under transfer pricing rules. A transaction is controlled or enterprises are associated if one enterprise participates in the management, control, or ownership of another enterprise, or if the same people or enterprise participates in the management, control, or ownership of two enterprises (i.e., a situation with common ownership).
Are there exemptions?
A growing number of countries are implementing contemporaneous transfer pricing documentation requirements, meaning the transfer pricing documentation has to be prepared prior to the filing of the tax return for a given accounting period. However, certain jurisdictions do provide documentation exemptions for small and medium-sized enterprises. In addition, a handful of other countries do not require contemporaneous documentation. While these exemptions exist, the burden of proof remains with the taxpayer to demonstrate arm’s-length pricing. This supporting information may still be requested during a transfer pricing examination, and the intercompany pricing may be adjusted by the examiner to reflect an arms-length outcome.
How do you calculate transfer pricing?
As noted above, associated enterprises should price transactions in the same way that uncontrolled entities would price the same transactions under similar circumstances. In short, the arm’s-length principle requires the comparison of controlled transactions with uncontrolled transactions. Hence, transfer prices are calculated through “comparability analysis” or benchmarking analysis. Valid comparables or benchmarks may exist as transactions between an associated enterprise and third parties (i.e., internal comparables). Alternatively, external comparables may be applied in the form of external comparable uncontrolled transactions (where none of the parties involved are members of the MNE group) or independent comparable companies that perform similar functions to one of the associated enterprises (i.e., the tested party). Our transfer pricing specialists can evaluate the specified transfer pricing methods and comparability criteria to identify the most reliable transfer pricing approach for a specific client. For external comparables, our transfer pricing specialists have access to specially licensed databases to conduct our benchmarking research. Please contact your nearest Kreston Global office to assist with your transfer pricing compliance needs.
Is transfer pricing tax evasion?
The objective of transfer pricing rules is to prevent MNEs from arbitrarily shifting income to avoid paying taxes. According to the OECD Guidelines, the consideration of transfer pricing should not be confused with the consideration of problems of tax fraud or tax avoidance, even though transfer pricing policies may be used for such purposes. Application of transfer pricing in accordance with the arm’s-length principle and the preparation of supporting documentation is considered to maintain tax compliance and good practice; failure to do so may result in income adjustments, potential double taxation, interest, and penalties.
How can Kreston Global help my company with transfer pricing?
Kreston firms can help support your company to adhere to country-based transfer pricing rules with the following core services:
Develop and/or optimize your transfer pricing methodologies with our planning expertise and benchmarking solutions.
Assist with transfer pricing documentation to ensure compliance with country specific regulations.
Perform analysis and modelling of intercompany services charges.
Perform benchmarking searches for royalty and license agreements, intercompany interest rates and comparable company samples.
Perform valuations of intellectual property and evaluations of migration strategies.
Please search for your nearest Kreston Global office here and they can help signpost you to the countries you need support in.
Wee Kwang is a Chartered Accountant of Singapore, a Certified Internal Auditor with the Institute of Internal Auditors and a Certified Sustainability Reporting Specialist with the Institute of Certified Sustainability Practitioners.
He has more than 20 years of experience in auditing and assurance and was involved with implementing the Sarbanes-Oxley framework for American-related corporations during his three-year secondment in London with a Big 4 accounting firm. He has also undertaken and led engagements in internal audit, enterprise risk management and sustainability reporting for companies listed on the Singapore Exchange and Growth Enterprise Market board of the Stock Exchange of Hong Kong as well as charitable organisations. He has spoken on various platforms on the topic of sustainability reporting.
He was treasurer of Yuhua Citizen’s Consultative Committee from 2013 to 2019. He holds a Bachelor of Accountancy from NTU.
Kreston ACA PAC partners future thoughts on ESG and audit
Koh Wee Kwang, partner at Kreston ACA PAC recently shared his views with the International Accounting Bulletin in the world survey. He was asked to comment on accountancy firms’ transparency to environmental, social and governance plans to prove their sustainability on the planet and society. His thoughts are that auditors could be in an advanced position with clients as they will be able to influence the boards with their ESG strategy. Read the full article below.
This includes an interesting read on the most recent economical changes in the United Kingdom. Also, a knowledgeable insight into national insurance rises, fuel duty and taxes.
News
Kreston’s Clive Owen LLP appoints new tax partner
April 19, 2022
Clive Owen LLP, chartered accountants and business advisers have appointed David Baggaley as a fifth Tax Partner at the rapidly growing firm.
David joins the firm, which has offices in Darlington, Durham, Middlesbrough, and York, from EY where he was an associate partner leading the private tax team in the North East and Yorkshire providing tax advice to both corporates and individuals.
A chartered accountant and chartered tax adviser with many years of experience in UK taxation, David spent time on secondment to EY’s offices in Bangalore, India and Edinburgh gaining valuable knowledge. He also has a keen focus on business development through networking.
Across the four offices currently, the firm now employs 117 people. The Clive Owen tax team has four tax partners, nine fully qualified chartered tax advisers and four trainee-chartered tax advisers, within the 17 strong team, making it one of the largest independent tax teams in the region. In addition, further appointments are set to be made in the coming months to add further depth to the tax team.
Growth is something very much on the agenda for the firm. They opened their fourth office on Riverside Park in Middlesbrough earlier this year with a 20-strong team at the 3,000 square foot site. The new office will provide more space to grow the business across the Tees Valley where they already have a significant number of existing clients and an appetite to develop further.
David Baggaley said:
“I am very pleased to be joining such a well-respected firm as Clive Owen. The firm has an entrepreneurial client base which I know I will very much enjoy working with.”
“It is a very exciting time for Tees Valley with Freeport status and the Treasury and other Government departments which are relocating part of their functions to Darlington. Clive Owen is very well placed to take advantage of the resurgence of the area, and I am looking forward to playing my part in this.”
Gary Ellis, managing partner said:
“David is an exceptional appointment who will further strengthen our excellent tax team. The firm has won a significant amount of new client work and seen an increase in demand from existing clients for tax advisory projects including re-organisations, R&D tax relief claims and inheritance tax advice and a tax partner of his calibre will help support the firm as we drive further growth.
I’m delighted to welcome David to the Clive Owen team at such an exciting juncture for us. His expertise and experience will be an asset as we develop the partnership going forwards”
News
Kreston Ukraine plans for the future
April 17, 2022
The Marshall plan initiative, created by members of Kreston Ukraine, is a critical part of economic recovery. A robust strategy will give the economy a chance to recover when the war one day comes to an end.
Liza Robbins, Chief Executive, Kreston Global and Sergey Atamas, Managing Partner, Kreston Ukraine report.
News
Andrew Collier
Director, Quality Control and Professional Standards, Kreston Global
Andrew is an experienced qualified chartered accountant who specialises in the technical and quality aspects associated with professional services in an international environment.
Andrew previously held the role of Technical Manager at RSM International and is proactively involved with several industry bodies as a member of the ACCA Global Audit Forum and The Transnational Auditors Committee (TAC).
Investigation into preserving audit independence
April 14, 2022
Andrew Collier our Director of Quality and Professional Standards, Kreston Global comments regarding whether audit firms should be prevented from cross-selling consultancy services to audit clients. Read here.
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