Does your business operate in multiple countries? Well, whether you like it or not, many local and international tax authorities inspect your tax strategy. Legal, effective tax planning is perceived as a “moral” issue. CEOs are being asked to testify on their process of tax transfer pricing between multinational legal entities.
Marc Seewald, Senior Director of Product Management for EPM Applications specializing in all tax subjects and Product Manager for Oracle Hyperion Tax Provisioning, and Bart Stoehr, Senior Director of Product Strategy for Oracle Hyperion Profitability and Cost Management joined me for a discussion/podcast on this interesting subject.
So what exactly is “tax transfer pricing”? Marc defined it this way. “Tax transfer pricing is a profit allocation methodology required to be used by multinational corporations. Specifically, the ultimate goal of the transfer pricing is to ensure that the global multinational pays their fair share of income tax in each of their local markets. Specifically, it prevents companies from unfairly moving profit from ‘high tax’ countries to ‘low tax’ countries.” According to Marc, in today’s global economy, profitability can be significantly impacted by goods and services exchanged between the related divisions within a single multinational company.
To ensure that these cost allocations are done fairly, there are rules that govern the process. These rules ensure that intercompany allocations fairly represent the actual nature of the businesses activity- as if two divisions were unrelated - and provide a clear audit trail of how the costs have been allocated to prove that allocations fall within reasonable ranges.
What are the repercussions of improper tax transfer pricing? How important is it? Tax transfer pricing allocations can materially impact the amount of overall corporate income taxes paid by a company worldwide, in some cases by hundreds of millions of dollars! Since so much tax revenue is at stake, revenue agencies like the IRS, and international regulatory bodies like the Organization for Economic Cooperation and Development (OECD) are pushing to reform and clarify reporting for tax transfer pricing. Most recently the OECD announced an “Action Plan for Base Erosion and Profit Shifting”. As Marc explained, the times are changing and companies need to be responsive to this issue.
“It feels like every other week there is another company being accused of avoiding taxes,” said Marc. Most recently, Caterpillar was accused of avoiding billions of dollars in taxes. In the last couple of years, Apple, GE, Ikea, and Starbucks, have all been accused of tax avoidance. It’s imperative that companies like these have a clear and auditable tax transfer process that enables them to justify tax transfer pricing allocations and avoid steep penalties and bad publicity.
Transparency and efficiency are what is needed when it comes to the tax transfer pricing process. Bart explained that tax transfer pricing is driving a deeper inspection of profit recognition specifically focused on the tax element of profit. However, allocations needed to support tax profitability are nearly identical in process to allocations taking place in other parts of the finance organization. For example, the methods and processes necessary to arrive at tax profitability by legal entity are no different than those used to arrive at fully loaded profitability for a product line. In fact, there is a great opportunity for alignment across these two different functions.So it seems that tax transfer pricing should be reflected in profitability in general. Bart agreed and told us more about some of the critical sub-processes of an overall tax transfer pricing process within the Oracle solution for tax transfer pricing. “First, there is a ton of data preparation, enrichment and pre-allocation data analysis that is managed in the Oracle Hyperion solution. This serves as the “data staging” to the next, critical sub-processes. From here, we leverage the Oracle EPM platform’s ability to re-use dimensions and legal entity driver data and financial data with Oracle Hyperion Profitability and Cost Management (HPCM). Within HPCM, we manage the driver data, define the legal entity to legal entity allocation rules (like cost plus), and have the option to test out multiple, simultaneous tax transfer pricing what-if scenarios. Once processed, a tax expert can evaluate the effectiveness of any one scenario result versus another via a variance analysis configured with HPCM’s pre-packaged reporting capability known as Oracle Hyperion SmartView for Office.”
Further, Bart explained that the ability to visibly demonstrate how a cost or revenue has been allocated is really helpful and auditable. “HPCM’s Traceability Maps are that visual representation of all allocation flows that have been executed and is the tax transfer analyst’s best friend in maintaining clear documentation for tax transfer pricing audits. Simply click and drill as you inspect the chain of allocation definitions and results. Once final, the post-allocated tax data can be compared to the GL to create invoices and journal entries for posting to your GL system of choice. Of course, there is a framework for overall governance of the journal entries, allocation percentages, and reporting to include necessary approvals.”
Lastly, Marc explained that the key value in using the Oracle Hyperion solution for tax transfer pricing is that it keeps everything in alignment in one single place. Specifically, Oracle Hyperion effectively becomes the single book of record for the GAAP, management, and the tax set of books. There are many benefits to having one source of the truth. These include EFFICIENCY, CONTROLS and TRANSPARENCY.So, what’s your tax strategy? Why not automate the tax transfer pricing process!To listen to the entire podcast, click here.To learn more about Oracle Hyperion Profitability and Cost Management (HPCM), click here.
