United States

U.S. Tax Reform: Transfer Pricing Implications for Japanese Companies

Wednesday April 11, 2018 3:00 PM - 4:30 PM EDT
From Global Enterprise Institute

KPMG Global Enterprise Institute

Event Overview

Please note that this Webcast will be presented in Japanese only.

KPMG LLP cordially invites you to a 90-minute audio Webcast that will cover transfer pricing implications of U.S. tax reform for Japanese companies.

On December 22, 2017, the U.S. president signed into law H.R. 1, (i.e. the Tax Cuts and Jobs Act). This act contains several tax rules affecting multinational companies’ cross-border transactions, which affect the value chains and transfer pricing arrangements of Japanese multinational companies. This seminar will utilize case studies to illustrate how intercompany transactions and value chains may be impacted by the tax reform.

Key discussion topics include:

  • High-level overview of the tax rules affecting cross-border transactions
  • Case studies including: 1) Types of transactions and implications of FDII (Foreign-Derived Intangible Income); 2) Consideration for GILTI (Global Intangible Low-Taxed Income); 3) A case related to BEAT (Base Erosion Anti-Abuse Tax) and its application; and 4) A case affecting inter-company profit allocation based on a change in functions, assets, and risks of entities involved in intercompany transaction.

 

Tomotake Naka

Managing Director, Economic & Valuation Services, KPMG LLP (U.S.)

Shigenori Iwaki

Senior Manager, Economic & Valuation Services, KPMG LLP (U.S.)