TPA Global (web) Events 2018

"Standardising Cost Recharges Post BEPS"

After BEPS, another topic that has received significant attention has been that of intra-group services defined in Chapter VII of the OECD TP guidelines. While some clarity has been provided on the mark-up to be applied for low value adding services, some additional requirements have also been set forth on what types of costs can be pooled, who can effectively receive a recharge, how to classify pass-through costs etc. For large multinational groups involved in providing cross border services to each other, this often translates to administrative inconvenience and issues with deductibility in certain countries.

Now that real-time reporting of tax related data is becoming a reality, multinationals also need to be proactive in efficiently managing their cost structures both from an efficiency point of view as well as to prepare themselves from questions from the tax authorities of countries receiving a recharge.

TPA Global has been using a “3x3x3 model” especially with large multinationals (of operations in more than at least 10 countries) to:

  • streamline intra-group service costs;
  • remove inconsistencies between categorisation of cost per service;
  • appropriate allocation of costs to legal entities;
  • prepare a defense strategy.

Some key attributes of the 3x3x3 model are:

  • It classifies group entities into three regions i.e. US, EMEA and APAC and a regional shared service centre is appointed per region. 
  • It classifies services into three categories i.e. Global HQ services, Global Business Unit specific services and Regional Shared Service Centre services. 
  • It classifies entities involved in these transactions into three categories i.e. Contract Service provider, Lead Service Provider and Service Recipient. 

TPA Global will be hosting two webinars on this topic: one to provide an explanation of the practical application of the 3x3x3 model and second, to provide guidance on how to automate this process.

Webinar #1 - Thursday, 27 September, 2018

9:00 AM - 10:00 AM Mexico, USA and Canada
11:00 AM - 12:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow

This first webinar will consider the following:

  1. What is the 3x3x3 model?
  2. What types of services can the 3x3x3 model be applied to?
  3. How to classify an entity as lead or a contract service provider?
  4. How to identify costs that can be recharged as per OECD (and selected country) guidance?



Webinar #2 - Thursday, 11 October, 2018

9:00 AM - 10:00 AM Mexico, USA and Canada
11:00 AM - 12:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)
6:00 PM - 7:00 PM Moscow

This second webinar will consider the following:

  1. What makes the 3x3x3-model easy to standardize?
  2. How can automation help you in implementing the 3x3x3-model?
  3. What are the steps involved in automation?
  4. How to identify workflows to be automated and who within your team should be made responsible for the process?

In this regard, TPA will provide a demonstration (using the TaxTimbre software) of automation of the 3x3x3 model, giving you new insights in the technology and possibly assisting you to adequately respond to today’s demanding tax and transfer pricing challenges.



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