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Fundamentals of Transfer Pricing
Fundamentals of Transfer Pricing
Transfer Pricing

Transfer Pricing is arguably the most important tax issues faced by international companies and tax administrations. This course will examine the principles of transfer pricing and its practical application by companies based in the MENA region.

Fundamentals of Transfer Pricing

By the end of this course, participants will:

  • Understand the importance and principles of international transfer pricing in their professions.
  • Evaluate transactions of international cross border exchange of good, services and intangibles Identify the significance of a unified international political approach through the BEPS project.
  • Appreciate the focus of Government on transfer pricing in the Middle East and North Africa.
  • Proactively comply and implement processes and policies with future anticipated regulations
Fundamentals of Transfer Pricing

This course is ideal for executive management including finance, legal, procurement and tax personnel of multinational enterprises, tax compliance specialists, management accountants, economists, lawyers, in-house tax managers, tax and transfer pricing advisers and consultants, government economic policy officials and tax department officers.

Course structure

The seminar will cover the latest international transfer pricing rules and its impact in the Middle East and North Africa:

Impact of transfer pricing in the MENA region:

Until recently the Middle East and North Africa region did not consider transfer pricing as a high priority on their government agendas. However, the significant international emphasis on the BEPS project (Base Erosion Profit Shifting) has encouraged governments across the MENA region to consider updating their legislation.

BEPS project was commissioned by the G20 and coordinated by the OECD in 2008 which has highlighted transfer pricing issues and become top priority with fiscal authorities and politicians worldwide when dealing with international intercompany cross border commercial transactions between their countries and others.

Specifically, Saudi and Egypt have introduced revised legislation which presents several tax and legal challenges for multinational enterprises operating in this region. In view of the above, multinational enterprises and government organizations should proactively prepare to manage the challenges arising when aligning with revised transfer pricing rules.

Specific transfer pricing areas that will include:

  • Introduction and importance to multinational groups and tax administrations
  • OECD guidelines, the BEPS project and approach in the MENA region
  • Legislative framework in the MENA region 
  • Arm’s length principle: Concept of comparability and the transfer pricing methods
  • Transfer pricing documentation: Content, purpose, guidelines, master and local file, country by country reporting
  • Transfer pricing dispute avoidance and resolution.
  • Mechanisms for avoidance and resolution of transfer pricing disputes
  • Advance pricing agreements, mutual agreement procedure and arbitration
  • Transfer pricing impact over the business:
  • Specific issues for transfer pricing of goods and services, intangibles and financing
  • Compliance, implementation and monitoring of risk management
  • Ongoing costs in maintaining a robust contemporaneous environment
  • Controversies

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