Taxation > Tax Transfer Pricing

Tax Transfer Pricing

Course Objectives

Explain in detail the transfer pricing framework and core concepts
Understand the five methodologies for determining arm’s length pricing from a managerial and a tax administration perspective
Discuss the merits of arm’s length pricing methodologies and latest initiatives in the 2017 OECD Transfer Pricing Guidelines (post Base Erosion Profit Shifting guidance)
Improved understanding of the business value chain and its connection to functional analysis in connection to global strategies
Appreciate the relationship between transfer pricing and other areas of tax law (e.g., GAAR, customs duty and GST
Understand key domestic and international case law developments in the context of transfer pricing
Prepare transfer pricing documentation, compliant with latest requirements of revenue authorities
Use of appropriate data in comparability studies that support pricing outcomes
Understand the importance of analysing statutory and management accounts to detect transfer pricing risks

Target Audience

Chief Financial Officers, Financial Controllers, Finance Managers, Accountants, Tax Consultants, Company Secretaries, Tax Practitioners/Advisors.

Methodology

Interactive Lectures, Discussions and Case Studies

Course Modules

Module 1 – Introduction to transfer pricing and international business strategies
Module 2 – Transfer pricing methods, Comparability analysis with economic and industry considerations
Module 3 – Transfer pricing documentation requirements and transparency initiatives
Module 4 – Transfer pricing risk management and tax audit techniques to Understand Financial Accounts
Module 5 – Transfer pricing intangibles, including Hard to Value Intangibles (HTVI) and cost contribution agreements (CCA)
Module 6 – Transfer Pricing Issues in Developing Countries
Module 7 – Intra-group services and offshore service hubs, Business restructurings (BRs) and Intra-group finance transactions
Module 8: Mechanisms for resolution of transfer pricing disputes, Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APA).

Get To Know The Trainer

Trainer Salmah

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Salmah is a trainer in the industry’s training delivering accounting, banking, taxation and banking training for individual with business and non-business income

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