Transfer pricing seminars
Global trade has significantly increased, creating an unprecedented level of integration in recent years. Globalisation and the rapid growth of international trade results in intercompany pricing becoming an everyday necessity. Increasingly, local and international tax authorities review these types of transactions in more detail, seeking to avoid abuses and avoidance channels. With changes in international tax environment, transfer pricing has become a complex area for many businesses.
Our seminars are addressed to CFOs, finance team members, tax advisors, accountants and lawyers. Our seminars will provide such professionals with solid knowledge of the key concepts and techniques of transfer pricing in order to achieve full compliance with the requirements of the new TP Regulations and mitigate the transfer pricing risk exposure.
Module 1
Transfer Pricing
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Session1
The Arm’s Length Principle (ALP)
- The Arm’s Length Principle (ALP)
- The OECD guidance on the application of the ALP
- Scope of Transfer Pricing control
- Pros and cons of the arm’s length principle
- Global formulary apportionment
Session2
Comparability analysis
- Nine step-approach in performing comparability analysis
- Comparability factors (economically relevant characteristics)
- Functional analysis and characterization of the parties involved in the controlled transactions
- Difficulties in identifying “perfect” comparables
- Adjustments performed to increase comparability
Session 3
Transfer Pricing Methods
- Comparable Uncontrolled Price (CUP) Method
- Resale Price Method
- Cost plus (C+) Method
- Transactional Net Margin Method (TNMM)
- Transactional Profit Split Method
Session 4
Transfer Pricing Documentation
- Transfer pricing compliance
- The three-tiered approach to TP documentation
- Local requirements on TP Documentation
- Transfer pricing audits
Module 2
Intra-group transactions involving services
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- Special considerations regarding the pricing of intra-group services
- OECD recommendations regarding the documentation of intra-group transactions involving services
- Selection of the most appropriate method for the documentation of transactions involving services
- Low-value adding intra-group services
Module 3
Intra-group transactions involving intangibles
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- Types of transactions involving intangibles
- Functional analysis in transactions involving intangibles
- Selection of the most appropriate method for the documentation of transactions involving intangibles
- Selection and application of the most appropriate method in transactions involving licensing / sale of IP
Module 4
Intra-group financials transactions
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- Types of intra-group financing transactions
- Transfer pricing methods for the documentation of related party fianncign transactions
- Intra-group loans
- Cash pooling
- Financial guarantees
