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International Tax Services (ITS) provides corporate income tax advice on all aspects of cross- border transactions, including financing and structuring, transfer pricing, and operating model effectiveness. A global network of international tax professionals helps clients manage their business tax responsibilities, including managing global tax risks and meeting cross-border reporting obligations. The EY Global Tax Desk Network is market-leading and provides worldwide up-to-date, country- specific knowledge and information. International Tax Services Services offered Key triggers BEPS Risk Analysis and Advisory Adjust your aperture Are you ready to meet country-by-country tax reporting requirements? In a globalized world, there are changes coming from many directions and at a high speed. Therefore, it is important for a multinational corporation (MNC) to be able to identify trends and their impacts as early as possible. The Base Erosion and Profit Shifting (BEPS) project of the Organisation for Economic Co-operation and Development (OECD) has rapidly moved to the implementation phase, leaving a fundamentally changed landscape in its wake. This new environment requires businesses to re-evaluate their operational and financing structures, identify communications strategies, and assess their tax strategy, all with the aim of developing a sustainable tax framework. Our professionals can help clients to be updated and prepared through a BEPS risk analysis, which can cover all or individual aspects of the plan. This will assist clients in evaluating how the plan will affect their business and in developing appropriate and effective response strategies. MNCs seeking advice on current international tax developments, e.g., the OECD BEPS project MNCs reviewing their international intangible property strategy MNCs wishing to rationalize or simplify their corporate structure MNCs concerned about the risks of tax nexus due to expansion into new territories or change of rules Cross-Border Direct Tax Advisory Services Worldwide Corporate Tax Guide 2015 Core international tax advisory focuses on non-deal- related cross-border direct tax issues, such as holding company structuring; cross-border treasury and finance; intangible property development, ownership and use; the ramifications of withholding taxes on cross-border payments; cash repatriation in cross-border situations; reorganizations or legal entity rationalization with a cross- border component; and risk of creating a tax nexus in connection with presence overseas. Furthermore, we assist clients with post-merger integration and multiple jurisdiction rationalization. MNCs examining their international corporate structure MNCs examining cross-border corporate treasury and finance operations MNCs requiring advice on withholding taxes on cross-border payments MNCs examining their overseas cash repatriation strategy Transfer Pricing Advisory Worldwide Transfer Pricing Reference Guide 2014 International business is faced with increasing transfer pricing documentation requirements, together with changing laws and regulations. Our Transfer Pricing (TP) teams help clients review, document, manage and defend their transfer pricing policies and processes — aligning them with the client’s business strategy. Our professionals work with the client to build the proactive, pragmatic and integrated strategies that address the tax risks of today’s businesses and help our client’s business achieve its potential. We also help clients to document their transfer pricing policies in a coherent and consistent fashion. MNCs with foreign operations wanting to achieve long-term tax and business benefits through integrated transfer pricing solutions MNCs with an international supply chain requiring TP documentation that complies with the various countries’ transfer-pricing documentation and penalty rules MNCs with cross-border treasury operations requiring advice on transfer pricing implications

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International Tax Services (ITS) provides corporate income tax advice on all aspects of cross-border transactions, including financing and structuring, transfer pricing, and operating model effectiveness. A global network of international tax professionals helps clients manage their business tax responsibilities, including managing global tax risks and meeting cross-border reporting obligations. The EY Global Tax Desk Network is market-leading and provides worldwide up-to-date, country-specific knowledge and information.

International Tax Services

Services offered Key triggersBEPS Risk Analysis and Advisory

Adjust your aperture Are you ready to meet country-by-country tax reporting requirements?

In a globalized world, there are changes coming from many directions and at a high speed. Therefore, it is important for a multinational corporation (MNC) to be able to identify trends and their impacts as early as possible. The Base Erosion and Profit Shifting (BEPS) project of the Organisation for Economic Co-operation and Development (OECD) has rapidly moved to the implementation phase, leaving a fundamentally changed landscape in its wake. This new environment requires businesses to re-evaluate their operational and financing

structures, identify communications strategies, and assess their tax strategy, all with the aim of developing a sustainable tax framework. Our professionals can help clients to be updated and prepared through a BEPS risk analysis, which can cover all or individual aspects of the plan. This will assist clients in evaluating how the plan will affect their business and in developing appropriate and effective response strategies.

• MNCs seeking advice on current international tax developments, e.g., the OECD BEPS project

• MNCs reviewing their international intangible property strategy

• MNCs wishing to rationalize or simplify their corporate structure

• MNCs concerned about the risks of tax nexus due to expansion into new territories or change of rules

Cross-Border Direct Tax Advisory Services

Worldwide Corporate Tax Guide2015

Core international tax advisory focuses on non-deal-related cross-border direct tax issues, such as holding company structuring; cross-border treasury and finance; intangible property development, ownership and use; the ramifications of withholding taxes on cross-border payments; cash repatriation in cross-border situations; reorganizations or legal entity rationalization with a cross-border component; and risk of creating a tax nexus in connection with presence overseas. Furthermore, we assist

clients with post-merger integration and multiple jurisdiction rationalization.

• MNCs examining their international corporate structure

• MNCs examining cross-border corporate treasury and finance operations

• MNCs requiring advice on withholding taxes on cross-border payments

• MNCs examining their overseas cash repatriation strategy

Transfer Pricing Advisory

Worldwide Transfer Pricing Reference Guide2014

International business is faced with increasing transfer pricing documentation requirements, together with changing laws and regulations. Our Transfer Pricing (TP) teams help clients review, document, manage and defend their transfer pricing policies and processes — aligning them with the client’s business strategy. Our professionals work with the client to build the proactive, pragmatic and integrated strategies that address the tax risks of today’s businesses and help our client’s business achieve

its potential. We also help clients to document their transfer pricing policies in a coherent and consistent fashion.

• MNCs with foreign operations wanting to achieve long-term tax and business benefits through integrated transfer pricing solutions

• MNCs with an international supply chain requiring TP documentation that complies with the various countries’ transfer-pricing documentation and penalty rules

• MNCs with cross-border treasury operations requiring advice on transfer pricing implications

Services offered Key triggersTransfer Pricing Controversy

2014 global transfer pricing tax authority surveyPerspectives, interpretations and regulatory change

Transfer Pricing Controversy services assist companies in managing and resolving disputes and other proceedings with tax authorities in relation to TP matters; in particular, these services include the provision of support with respect to:• Advance pricing agreements

• Audit defense

• Competent authority processes

• MNCs in dispute with tax authorities seeking advice

• MNCs aiming for greater certainty with respect to future tax treatment of transfer pricing policies

• MNCs with intercompany transactions of high volume and complexity requiring assistance

Intercompany Effectiveness (ICE)

Intercompany effectivenessA structured approach to forecast, implement, monitor and report intercompany transactions

EY | Assurance | Tax | Transactions | Advisory

About EYEY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities.

EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com.

© 2016 EYGM Limited.All Rights Reserved.

EYG no. 03075-161Gbl1608-2037823ED None

This material has been prepared for general informational purposesonly and is not intended to be relied upon as accounting, tax or otherprofessional advice. Please refer to your advisors for specific advice.

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This service offering is focused on verifying that a company’s books correctly reflect the transfer pricing methodology adopted and the resulting outcome. Our TP professionals will work with the companies’ IT and accounting system departments to test and validate the underlying accounting systems.

• MNCs seeking opportunities for simplification and process improvement

• MNCs seeking systems to meet requirements for setting and monitoring transfer pricing

Operating Model Effectiveness (OME)

Operating Model Effectiveness A competitive advantage

A variety of cost reduction and transformation trends are defining the business operations of the future. OME services assist companies in designing and implementing changes in operating models to deliver performance improvement within a tax-effective structure. For example, our multidisciplinary OME teams work on supply chain design, business restructuring, systems implications, transfer pricing, direct and indirect tax, customs and accounting with our clients.

• MNCs contemplating or implementing changes in their operating models, in particular those that:

• Are centralizing key business functions

• Are undertaking a reorganization or post-merger integration

• Have proposed the introduction of new ERP systems

EY key contactsAlex Postma Global ITS Leader +81 3 3506 1275 [email protected]

Jeffrey Michalak Americas ITS Leader +1 313 628 8460 [email protected]

Matthew Mealey EMEIA ITS Leader +44 20 7951 0739 [email protected]

Alice Chan Asia-Pacific ITS Leader +852 2629 3882 [email protected]

Jonathan Stuart-Smith Japan ITS Leader +81 3 3506 2426 [email protected]

Gerrit Groen EY ITS Global Tax Desk Network Leader+1 212 773 8627 [email protected]

Peter B Griffin EY Global and EY Americas Transfer Pricing Leader +1 612 371 6932 [email protected]

Oliver Wehnert EMEIA Transfer Pricing Leader +49 211 9352 10627 [email protected]

Curt Kinsky Asia-Pacific Transfer Pricing Leader +852 2629 3098 [email protected]

Ichiro Suto Japan Transfer Pricing Leader +81 3 3506 2637 [email protected]

Jay Camillo Americas OME Leader +1 404 817 5035 [email protected]

Joost Vreeswijk EMEIA OME Leader +41 58 286 2409 [email protected]

Edvard Rinck Asia-Pacific OME Leader +852 2849 9188 [email protected]

Yasuyuki Ogata Japan OME Leader +81 3 3506 2411 [email protected]

Tax Agenda A strategic discussion of your tax function

EY | Assurance | Tax | Transactions | AdvisoryAbout EYEY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities.

EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com.

© 2017 Ernst & Young LLP All Rights Reserved.

1701-2164272EYG SCORE No. 01087-173GBLED None

This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice.

ey.com