Financial, tax and operating personnel involved with or participating in the development of a company’s transfer pricing programme should attend this two-day workshop. The course provides a hands-on approach to transfer pricing methodologies, and examines practical solutions to common transfer pricing challenges including preparing a Transfer Pricing Study.
Day 1
Session 1 Transfer Pricing Project Planning and Strategy
Session 2 Analysing the Intercompany Transfers of Tangible Property
Available methodologies
How to determine when transactional methods are more reliable than profit based methods
Types of manufacturers and distributors
Examples of common intercompany transactions involving sales of tangible property
Session 3 Analysing Intercompany Services
When you must impute a profit or mark-up on service costs
Treatment of stewardship or other non-chargeable functions
Types of service providers
Examples of analysing common intercompany services transactions
Session 4 Analysing the Intercompany Transfers of Intangible Property
Definition of intangible property – who is the legal owner?
Examples of analysing common intercompany transactions involving intangible property
Session 5 Analysing Intercompany Financial Transactions
How to benchmark intercompany loans, guarantees, cash pooling arrangements and other intercompany financial transactions
Examples of analysing common intercompany financial transactions
Day 2
Session 1 Compliance & Penalties
Tax return reporting requirements (e.g. Americas, Africa, Asia, Europe and/or specific countries)
Overview of Transfer Pricing Penalties by selected countries
Session 2 Detailed Examination of the EUJTPF’s Master File and Country File
Session 3 Preparing a Transfer Pricing Study
Satisfying the requirements for contemporaneous transfer pricing documentation
Financial analysis
Risk-function analysis
Economic analysis
Determining the tested party
Session 4 Comparison of OECD Transfer Pricing Guidelines to other Transfer Pricing regimes
Session 5 Practical solutions to common transfer pricing issues