#EYInstaTakeOver – Eine Woche mit Nate in Zürich

Steuerrecht ist komplex. Vor allem über nationale Grenzen hinweg. Bei EY arbeiten Spezialisten wie Nate, der als Transfer Pricing Consultant in den Tax Services in Zürich tätig ist. Als Absolvent mit wirtschaftlichem und juristischem Hintergrund unterstützt er Mandanten dabei, die Herausforderungen internationaler Steuerfragen zu meistern. Welche Aufgaben dabei jeden Tag auf ihn warten, zeigt er in einem #EYInstaTakeOver, den wir hier für Euch zusammengefasst haben.

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Hi everyone, I'm Nate and it's my pleasure to give you some insights into my job as a Transfer Pricing (TP) Consultant with EY Zurich during the course of this week. With an academic background in both law and economics, TP is the perfect field for me – we deal with complex interdisciplinary questions that require quantitative and legal thinking on a daily basis. Another important aspect of our TP projects is #teamwork: not only with colleagues from our own practice, but also experts from many other specialist fields in #TAX, such as VAT, PAS (People Advisory Services) or OME (Operating Model Effectiveness). Btw, a #mondaymorning is so much better with #coffee and some #office_fun – table soccer is my favorite, I admit. Please reach out to me if you have any questions related to a career in tax in general or TP in particular – I'm happy to help!

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Today I am finalizing the benchmarking study for Clinical Trial Services of a major pharmaceutical company. The purpose of benchmarking studies is to determine the general conditions surrounding the transactions conducted by third parties on a given market. Such studies help elicit a range of values, i.e. the so-called arm's length range or mark-up range. When a transfer price determined by a taxpayer for a transaction is not found under the applicable arm's length range, the competent tax authority will usually determine the arm's length price of the transaction under review using the median value of that arm's length range. The final step in a benchmarking analysis is the preparation of a write-up that summarizes the entire search process, results and #EY's conclusions.

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Today, the entire #EY Transfer Pricing Team from Switzerland (i.e. all TP team members from the Geneva and Zurich offices) met up in Zurich to discuss how we can streamline our global TP documentation approach by leveraging the international network we have – #betterworkingworld!! FYI: Transfer pricing documentation is usually required by law. This documentation must substantiate how the intercompany business is set up and evidencing that the intercompany pricing applied would have been applied between third parties as well. In many countries taxpayers are obliged to have TP documentation when a taxpayer performs intercompany transactions. Depending on the jurisdiction this documentation should be submitted annually, where in other countries this documentation should be submitted upon request of the tax authorities or sometimes taxpayers are required to prepare contemporaneous documentation. Having adequate TP documentation available helps to prevent companies being confronted with a shift of the burden of proof with respect to TP adjustments imposed by tax authorities, as well as double taxation. Moreover, non-compliance with TP documentation requirements can sometimes lead to penalties.

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Good morning everyone – as promised, I brought some cheesecake to the office today. On this picture you can see the early birds of my team 😃 Matej from Slovenia, Bernadette from Germany, me (Swiss) and Maria from France. #EYDiversity #EYInternational … For the rest of the day I'll be working on a Master File. For the typical MNE, TP documentation is separated into two pieces: one portion (the Master File) that they will share with any and all tax authorities that ask for it, and another portion (the Local File) that contains information specific to a particular country. So the MF will generally contain descriptions of the global business, including products, services, and business strategies; the major entities in the group and what functions they perform; the general categories of controlled transactions that take place within the MNE group; the group's significant intangible assets and which entities are involved in their creation, management, or enhancement; and the group's financing structure as it relates to transfer pricing.

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The YTPY (#EYYoungTaxProfessional of the Year) 2011 international final in Paris, in which I participated as a country finalist of Switzerland, is one of my favorite #EY memories. We have been coached by amazing mentors and then had to present & discuss a case study in front of a top-class jury composed of people from academia, French tax authorities and the industry. Google for 'Young Tax Professional of the Year 2017' to learn more about how to take part in this amazing #eytaxchallenge. The second prize brought me to EY's Tax Center in London for ten days where I learned a lot about EY's international tax services. Btw, the award ceremony took place in the opera in Paris 😃 I can only encourage you to seize the opportunity and participate in the next local competition – #eysetsail … Please reach out to me if you have any questions on how to prepare for the next YTPY, I'm happy to help!

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Earlier this week I told you about the CFA. Several other people in our TP (transfer pricing) practice study hard to become Swiss Certified Tax Experts: the activities of a tax expert are not limited to solving tax problems. These requirements demand a much more wide-ranging qualification. Tax experts must also deal with business and legal problems. Optimum tax planning requires a knowledge of all key business areas, such as proper financing for companies, the valuation of individual assets on a balance sheet or company valuations. In addition to material tax issues, tax experts also deal with procedural problems. This requires legal knowledge as well as an understanding of public administrative law. To provide the best tax advice, particularly in the area of retirement planning, tax experts must have an in-depth knowledge of social insurance law and new insurance products. Finally, a tax expert's professional activities require an in-depth, application-oriented knowledge of tax. #eycareers #tax #masteryourcareer

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Interessiert Ihr Euch auch für internationale Herausforderungen an unseren Standorten in der Schweiz? Alle Infos zum Einstieg findet Ihr auf der Karriereseite.

 

 


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