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Next generation documentation for BEPS, TCJA and beyond

February 28, 2019 @ 1:00 pm - 2:30 pm EST


Participants of the live webinar will be eligible for 1.5 free CPE credit.


Transfer pricing (TP) documentation historically has been confined to the documentation requirements under the Section 6662(e) regulations and foreign equivalents.

The Organisation for Economic Co-operation and Development base erosion and profit shifting (OECD BEPS) initiative added to those documentation requirements, but more fundamentally has forced multinationals to think more strategically about documentation. The US Tax Cuts and Jobs Act (TCJA) has also added new dimensions to consider for effective documentation, such as supporting appropriate basketing for foreign tax credit purposes, documenting the services cost method (SCM) exception to the base erosion and anti-abuse tax (BEAT), determining BEAT implications for notional dealings under the Authorized OECD Approach (AOA), and evaluating how statistical sampling can reduce costs and enhance reliability of documentation. The EU is getting into the act as well with the new Mandatory Disclosure Regime.

This webcast will cover:

  • “Traditional” TP documentation in a post-BEPS world
  • Analysis and documentation for foreign branches and permanent establishments (PEs) of US companies
  • Analysis and documentation for US branches and PEs of foreign companies under the AOA
  • Documenting SCM for purposes of the BEAT exclusion
  • Using statistical sampling to support the SCM BEAT exclusion
  • The EU’s Mandatory Disclosure Regime

We hope you will be able to join us for this important webcast.


  • Tom Ralph, Transfer Pricing, Ernst & Young LLP
  • Tara Riccio, Transfer Pricing, Ernst & Young LLP
  • Ryan Petska, Quantitative Economics and Statistics (QUEST), Ernst & Young LLP


  • Mike McDonald, Transfer Pricing, Ernst & Young LLP


February 28, 2019
1:00 pm - 2:30 pm
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