Transfer Pricing Masterclass

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Transfer Pricing Masterclass

USD 995

Day 1 - How to run your transfer pricing compliance process smoother

Session 1 - Setting the scene

• The TP life cycle and where documentation fits in.
• The relevance of TP for tax purposes, audit and corporate reputation (i.e. the cost of getting it wrong)
• Factors that determine a company to be in control of their TP position.
• Determining the comfort level of the TP position against the risk tolerance level of the company.

Session 2 - The (changing) reference framework

• The current and past prevailing international principles for allocating profit to activities (enabling you to recognise whether your policies are outdated)
• The prevailing reference frameworks and where they -sometimes- differ (obtain an understanding of the different interpretations by various tax authorities)

Session 3 - TP design

• The TP methods and the importance of choosing the appropriate method
• How to choose the appropriate method (functional analysis and common business models, i.e. manufacturing, distribution, procurement)
• How functional price testing works
• Benchmarking analysis explained

Session 4a - TP Implementation

• How transactional price setting works (for service providers, distributor and manufacturer activities)
• Year-end adjustments, what risk they bring and how to mitigate these risks
• The potential of technology in setting and adjusting your TP’s

Session 4b - TP Implementation

• Case study on how to align the relevant stakeholders within a company to mitigate the effects of  post-year-end TP adjustments and as a result lower the tax at risk, run a smoother compliance process, have an accurate reflection of the TP position in the financial accounts, and reduce the key-person-risk.

Day 2 - Transfer pricing for common business models
 

Session 1 - Setting the scene

• Choosing the location of your (regional) head quarter
• ○ The main -tax- features of a holding regime (tax rate, participation exemption, domestic WHTs, treaty network and -advanced- certainty) and how they can be affected by TP.
• ○ UAE – CIT regime (incl. FZ – substance requirements)
• ○ KSA – CIT regime (incl RHQ – substance requirements)

Session 2 - The remuneration of the HQ functions

• Low and high value adding services
• Procurement companies (who gets the synergy benefit and how sustainable is the centralisation of profits of high value add services)

Session 3 - The remuneration of the Principal functions

• The Principal model explained
• Implementing a Principal office (PE issues, exit goodwill)
• The contracting Principal (local content, re-invoicing companies, title of transactions)
• the R&D Principal

Session 4 - The remuneration of the treasury function

• Intercompany loans (shareholder loan, loan pricing, financial conduit companies),
• cash pooling arrangements (the effect of group rating and how this impacts the remuneration of the cash pool leader)

Session 5 - Related parties

• OECD criteria / Domestic rules
• Joint ventures (why are they considered related parties)
• Government owned entities (UAE and KSA rules)

Session 6 - Audit management and dispute resolution

• Common observed audit risks
• The instruments to avoid double taxation and how to choose the right instrument
• Tax audit risk management i.e. communication protocol, sharing of documents, statute of limitations, burden of proof, penalties, etc.