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Deloitte Academy, Webinar12 May 2020
Functional P&L Segmentation A component of Operational Transfer Pricing
© Deloitte Academy 2020 2
Deloitte Academy series of webcasts
Functional P&L segmentation
• First, legal entities with multiple functional roles (egmanufacturing, distribution, finance and services) should segment their (statutory) P&L to reflect the income statement per functional role.
Define ERP requirements and End 2 End (E2E)processes
Defining the transfer pricing strategy and model
Dealing with the tax authorities
Documenting your approach and methodology
Recording outcomes in your books and recordsData
• Tax sensitized data with necessary data dimensions, suitably validated.
• Ability to easily incorporate and manipulate disparate data sources.
Processes
• Strong audit trail with clear responsibilities across functions.
• Clear and timely monitoring and adjustment processes.
People
• Correct skills set (tax, finance, IT) for now and the future.
• Clear alignment on objectives.
Overall, building blocks of a successful OTP solution
Automation of goods and services calculation
• Second, the pricing of intercompany transactions can be calculated based on (segmented) budgets. Actual margin management is key to timely identify variations in actual margins versus budgets. Automating manual tasks increase accuracy and efficiency.
Link between (O)TP and VAT/indirect tax
• Third, high variations may lead to significant TP adjustments which have VAT as well as customs consequences.
• Also, the implementation of specific TP models may have unexpected VAT implications.
System based TP audits / SAF-T
• Also, the ERP system should enable to produce audit ready files. Tax authorities are increasingly moving away from the traditional audit techniques of manual data processing, towards new and sophisticated e-audits. Tax authorities are also introducing the OECD-recommended Standard Audit File for Tax (SAF-T). ERP systems become more flexible and integrated to
facilitate automated solutions.
© Deloitte Academy 2020 3
Your speakers today
Jeroen Lemmens
Transfer Pricing Partner
Annelies Dieusaert
Tax Technology Partner
Koen Lombaerts
Transfer Pricing Director
Antoine Mounzer
Tax Technology Senior
© Deloitte Academy 2020 4
12 May 2020
Agenda - Functional P&L Segmentation
WHAT – Concepts
HOW – Approach
WHY – Relevance02
03
01
© Deloitte Academy 2020 5
Background
80%of global trade is now conducted between affiliated companies *
* See United Nations Conference on Trade and Development Press Release at: http://unctad.org/en/pages/PressRelease.aspx?OriginalVersionID=113
Operational Transfer Pricing the process of reflecting the TP policy in your books and records
Stakeholders Responsibilities
Data Systems
Processes Controls Workflow
TP
analytics
I/C
true-ups
Pricing
conditions
Cost
allocations
Budget +
forecast
VAT
returns
Audit
defence
CbC
return
Master &
local file
TP
policies
BUSINESS MODEL
KEY CONNECTORS DELIVERABLES
INTERNAL EXTERNAL
Functional segmented P&Lthe process of splitting an entity’s P&L across all the entity’s functional profiles
How ?What ? Why ?
© Deloitte Academy 2020 6
What is a functional segmented P&L
Legal entity
Business unit 1 Business unit 2 Business unit 3 …
LRD R&D G&A Agent Entrepreneur G&A Entrepreneur
Gross
Profit
OP
…
Fu
ncti
on
s
OM %Actuals
Benchmark OM %
NCP %
NCP %
NCP %
Gross
Profit
Gross
Profit
Overhead Overhead Overhead
OP OP
NCP %
Gross Profit
Overhead
OP
How ?What ? Why ?
© Deloitte Academy 2020 7
P&L segmentation concept
Legal
entity FFM LRD R&D
Business
unit G&A Agent
LE 1
LE 1
LE 2
BU 1
BU 2
BU 3
TP functions
Gross Profit
OP
OM %
Overhead
LRD
Gross Profit
OP
OM %
Overhead
R&D
Gross Profit
OP
OM %
Overhead
Agent
Link qualitative data..
.. with hurdles
.. to financial data ..
ERP are not configured for P&L segmentation at
operational profit level by function and there no
simple “plug-and-play” solution available for TP
purposes
Required data points for P&L segmentation can
be scattered across several data sources, which
makes collecting the required data complex and
time consuming.
No formally defined procedure and tool in place
for P&L segmentation makes it often a very ad-
hoc process with limited internal controls and
extensive manual intervention.
How ?What ? Why ?
© Deloitte Academy 2020 8
Why relevant and important
Complexity
High impact
Hand-offs between functions
Spreadsheet usage
Interaction with other taxes
Increased regulation – global and local
Stronger technology options
Better advisor expertise
Targeted audit focus
Systems-based audits
Greater public disclosure
Widening of disclosure requirements and thresholds
Further technology improvements
What’s coming
What’s new
What’s always been there
How ?What ? Why ?
© Deloitte Academy 2020 9
P&L segmentation world heat map
ArgentinaAustriaBangladeshColombiaDenmarkFranceGermanyGhanaGreeceHong KongHungaryIndonesiaIrelandIsraelItalyMalaysiaMexicoPolandRomaniaRussiaSerbiaSingaporeUkraineVietnam
BrazilSwitzerlandUnited Arab EmiratesMoroccoTurkey
AustraliaBelgiumCanadaCroatianNetherlandsEgyptFinlandIndia JapanKenyaLatviaNorwayPakistanPanamaPortugalSlovakiaSouth AfricaSouth KoreaSpainUnited KingdomUruguay
Strict P&L segmentation requirements
P&L segmentation can be requested during audit
No P&L segmentation provisions
How ?What ? Why ?
© Deloitte Academy 2020 10
P&L segmentation part of the transformation journey
JO
UR
NE
Y
Invoice booking in ERP
Configure master data
Run automated P&L segmentation
Analyze margins, document results
F u n c t i o n a l P & L s e g m e n t a t i o n
Automated
Lower cost
Higher value
Lower risk
Rapid execution
Invoice booking in ERP
Request data Extract and submit data
Manually transform, consolidate, analyse,
calculate, submit
Review, approve,and post
Manual
Higher cost
Lower value
Higher risk
Slow to execute
SCC Local FinanceLocal Finance Group Tax
Group TaxLocal Finance Local FinanceGroup TaxLocal Finance
How ?What ? Why ?
© Deloitte Academy 2020 11
Benefit case
• Proactive management of tax authorities
• Control over process in case of TP audit (limited manual input, automation, etc.)
• Ability to automate the TP documentationpreparation
• Time saved to be spent on tax strategy and analytics
• Ability to assist on proactive cash flow management
• Control over group ETR for financial reporting
• Improved intercompany flow insights
• Transparent and accurate analytics per functional segment (margin analysis)
• Connectivity across departments (FP&A, tax, controlling, supply chain)
• Coordination during accounting closings (change of transfer price, recharge invoices, true-ups)
• RACI model assigning clear responsibilities for all departments involved in TP processes
Finance team
Tax team
Other teams
How ?What ? Why ?
© Deloitte Academy 2020 12
When to discuss P&L segmentation How ?What ? Why ?
Our group is looking into finance cost reduction & finance transformation (free-up time of local finance resources & increase productivity)
Our group is looking at internal control / horizontal monitoring improvements to reduce risks and be compliant
Our group is implementing a new ERP system (SAP / CFIN implementation) and wants to look at the TP requirements (as part of the tax stream of the implementation)
Our group’s data source is scattered (many systems used, BW, ERP, Hyperion, Excel)
Our group has legal entities that encompass multiple functions from a TP perspective (e.g., limited risk distribution, provision of services, contract manufacturing, IP ownership) and is not able to gain insights in the profitability of each activity by lack of segmented P&Ls.
© Deloitte Academy 2020 13
P&L segmentation by TP segment method example
60 %
Gross margin
Overhead
Stat
adjustment
Data type Data source1
GM by product
P&L by LE
Stat reporting data
TP
segment
[M]
TP
segment
[LRD]
TP
segment
[G&A]
Legal entity
Business unit
70 % 20 %
30 %
10 %
10 %
Derivation rules to assign GM to TP segment based on GM report data
points (e.g. customer group, material group, delivery plant, sales org,..)
Allocation rules based on allocation keys (headcount, turnover, gross profit,..)
and cost center type
Allocation rules based on allocation keys (headcount, turnover, gross profit,..)
and adjustment type (account)
How ?What ? Why ?
© Deloitte Academy 2020 14
The backbone of the engine
Segments
• Legal entity
• Company codes
• Functions
Data Sets
• Legal entity P&L
• GL postings (EBIT level)
• GAAP To Stat Adjustments
• Data Set mapping
Data Points
• Entity/Plants
• Profit Center/Cost Center/products
• Accounts
• Counter parts
Allocation Rules
• Direct
• Indirect (via allocation keys)
• Manual
Allocation Keys
• External sources (e.g. headcounts report)
• Calculated (e.g. net sales)
Configure Upload
1. Segments
2. Data Sets
3. Data Points
4. Allocation rules
5. Allocation keys
1. Entity P&L
2. GL postings
3. Stat Adjustments
Process Export Reports
• Control & Reconciliation
• Analysis
• Reporting
1. Reconciliation items / Reclass
2. Manual allocation rules input
1. USGAAP Segmented P&L
2. Local GAAP Segmented P&L
3. Margin Analysis Reports
1
P&L Segmentation Tool
2 3 4
A B C D
E
F
How ?What ? Why ?
© Deloitte Academy 2020 15
Technology as an enabler
Global visibility for tax authorities
Systems-based audits for TP
Public disclosures Greater pressure for ETR stability
Pressure to mitigate other tax
costs
Clear strategy and policies
Senior stakeholder integration
Strong execution into books and records
Rapid and flexible execution
Analytics and scenario planning
Well formulated controls framework
Co-ordination with Investor Relations
Tech
no
log
yHow ?What ? Why ?
© Deloitte Academy 2020 16
Example of technology options for P&L SegmentationHow ?What ? Why ?
Fit with the process
Fit with the people
performing the process
Fit with the technology
landscape
Cost of ownership
(implementation, license,
training)
Audit trail & risk
avoidance
++
Excellent Poor
© Deloitte Academy 2020 17
P&L segmentation tool exampleHow ?What ? Why ?
© Deloitte Academy 2020 18
Where have we done this before
Case 2
Case 1 Case 3
Where did we assist ?
Automating the calculation of transfer prices per product and supply chain flow
Automating and streamlining the intercompany cost recharge processes (and the related budgeting)
Putting in place an audit trail to help defend the calculations and processes during TP audits
Client challenges
The client was suffering from very high year-end true-ups due to transfer prices on services and goods that were calculated only at the start of the financial year in a very simplistic way.
Where did we assist ?
Putting in place a P&L segmentation tool to automatically split the entity's P&L between the different routine function margins per business unit
Assessing pain points related to their current cost recharge processes
Putting together a business case to convince internal stakeholder of the need of a more centralized and standardized cost recharge process
Client challenges
Our client needed to provide the local tax authorities with a functional P&L segmentation in light of the recent TP legal requirements
Where did we assist ?
Client challenges
The client had issues controlling the transfer prices set between the routine distributors and manufacturing entrepreneurs due to the lack of financial and supply chain visibility.
Integrated the supply chain links and product costing of every SKU within the legal entity in a calculation model
Segmenting the P&L per product sold and selling entity to visualize the margins per SKU
Linking back the P&L per product sold and selling entity to the TP function to finalize the P&L segmentation
How ?What ? Why ?
© Deloitte Academy 2020 19
What’s next
Brainstorm for areas with these characteristics
• Voluminous data
• Significant time spent manipulating data
• Analysis on recurring basis
• Scenario analysis of alternatives
• Identification of most suitable technologies
Identify opportunities
Think big
Prioritize opportunitiesbased on
• Value
− Time savings/capacity enhancements
− Benefits derived
• Risk
• Ease of implementation
− Cost
− Data availability
− Resources
Pick one or two areas of focus
Start small
Get started with a proof of concept to help
• Socialize the benefit
• Identify hurdles and risks
• Identify available assets
• Educate on tools and change management
Prove it works(proof of concept)
Act fast
Next step: Consider a structured lab environment
How ?What ? Why ?
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Deloitte provides audit, tax and legal, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most complex business challenges. Deloitte has in the region of 286,000 professionals, all committed to becoming the standard of excellence.
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© Deloitte Academy 2020