Insights into transfer pricing in a global business environment

National Transfer Pricing Event

Transfer pricing is focused on ensuring that when different parts of a multinational group have dealings, transactions or interactions between them, the resulting tax outcomes are the same as they would have been, had two unrelated third parties been involved. It’s an important topic for practitioners working with large, global businesses to understand.

Edwin Baghdasarayan, ATI, Partner in the PwC Global Tax team, has been practicing in the transfer pricing space since 2007, when he started with PwC as a graduate. In that time, he has also been involved in thought leadership across a number of transfer pricing topics and chaired or presented sessions at The Tax Institute conferences.

We caught up with Edwin ahead of our upcoming 2020 National Transfer Pricing Online event to find out more about his area of expertise.

“I was first interested in transfer pricing as I had a passion for international business and economics throughout university. The topic of transfer pricing is an area which covers these aspects of business in detail,” Edwin explained.

“It is a discipline that touches aspects of law, economics, finance and accounting. It also is a topic which is gaining significant momentum over the last 5-10 years off the back of the OECD’s BEPS initiative.”

Edwin’s session, Part 3: Cross-border financing arrangements - The release of long-awaited consensus guidance, deals with the OECD’s long-awaited final paper on the transfer pricing aspects of financial transactions, released in February of this year.

It will cover key aspects and messages within the OECD paper and how this framework links in with the Australian transfer pricing rules, best practice approaches to analysing and pricing intercompany financing arrangements in accordance with the latest guidance and key aspects to consider when documenting and evidencing your position in the new world.

The ongoing globalisation and digitisation of business and impacts on transfer pricing

“With the increasing globalisation of business and the tax implications of this trend, the topic of transfer pricing is becoming more and more important for tax professionals, including tax authorities, multinational groups and academics alike,” Edwin said.

“This is further amplified with the OECD BEPS initiative, as well as more recent initiatives on Pillars 1 and 2, which guarantees a pace of change which has been unprecedented in both the Australian and global tax landscape.”

Edwin said that he is looking forward to hearing from Matt Andrew, representing the OECD and the panel in Part 7: Tax Challenges of Digitalisation. This session will first cover the latest developments concerning Pillar 1 and Pillar 2 from the OECD, followed by a panel discussion addressing topics including what the future looks like for transfer pricing rules if Pillar 1 is introduced, the likelihood and potential implications for multinationals of countries taking unilateral action on DST if consensus cannot be reached on Pillar 1 and the timing and implementation of Pillars 1 and 2.

According to Edwin this is, “…a topic which will become more and more relevant with the evolution of business.”

Attend the 2020 National Transfer Pricing

The 2020 National Transfer Pricing event takes place from 8 September 2020 to 8 October 2020. It includes 10 expert lead sessions, running the gamut of topical transfer pricing issues. Practitioners who attend the entire series can gain 10.5 CPD hours.

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About Edwin Baghdasarayan, ATI

Edwin Baghdasarayan

Edwin is a Transfer Pricing Partner within the PwC Australia Global Tax practice, based in Sydney. In particular, Edwin has extensive experience in transfer pricing consulting for financial transactions and has advised top listed multinationals across the entire transfer pricing lifecycle including consulting, structuring and planning, documentation, managing risk reviews, audits and unilateral/bilateral APAs.

When he isn’t thinking about tax matters, Ed’s two young children keep him on his toes. He always makes sure to take time out for travelling, exercise and, of course, following sporting teams.


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