Transfer Pricing Masterclass

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The goal of this masterclass is to familiarise those individuals who are responsible for transfer pricing (TP) within your organisation with the main principles and practical aspects of TP.

The course covers the processes of designing, implementing and managing your TP positions. It also explains the common technical issues in TP in a practical manner. It focuses on actual situations and how to solve those, referring to theory only when necessary for context. This training will create an understanding that allows you to have better conversations with both the stakeholders in the company and your external advisors, and will help you make better decisions in terms of what is relevant for your company, what can be done in-house, what needs to be outsourced and what you should expect in terms of delivery.

USD 895

Agenda

Day One

Setting the scene
What is TP
Why do you want to get it first time right
In control of the TP position

The AAL principle
A changing reference framework
OECD v UN
Geopolitical forces at play
Alternative models

TP design
TP methods
Business models
Value creation
Benchmarking

Intercompany services
HQ management
Group support services (LVA)
Intermediate financial and reinvoicing services
High value adding services - creating synergies
Intangibles

Threshold for taxable presence
Permanent establishments
Geographically dispersed management teams
Dependent agent PEs

Associated enterprises for TP purposes
The criteria
Joint ventures

Day Two

Implementation (price setting)
Introduction
From price testing to price setting
Goal seeking (price adjustments)
Transactional design

Financial transactions
Debt funding
Guarantee fees
Cash pooling
Captive insurance

Business restructuring
The purpose of the regulations
The regulations
The instruments
The post-BEPS impact

Dispute resolution
TP adjustments (primary, corresponding and secondary)
Instruments for dispute resolution
Effectiveness of available instruments

Compliance
Purpose and TP compliance aspects
Data quality and consistency with other information
Preparing the three tiered documentation

Pillar 2 and TP
High level overview of P2 rules
How P2 interacts with TP