A Practical Guide to Transfer Pricing
Course
In City of London
Description
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Type
Workshop
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Location
City of london
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Class hours
6h
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Duration
1 Day
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Start date
Different dates available
This course is intended as an ‘everyman’s guide’ to transfer pricing (‘TP’) and the arm’s length standard (the ‘ALS’). It covers the specifics of the UK legislation but focuses on OECD Transfer Pricing Guidelines which are generally regarded as offering the global standard for TP in OECD and most developed economies. It includes a discussion of what changes are likely to OECD practice in the TP area when OECD and the G20 countries ongoing Base Erosion and Profit Shifting (‘BEPS’) project concludes.
Facilities
Location
Start date
Start date
About this course
The course is intended not so much for transfer pricing professionals but as a primer for legal and tax advisors and finance personnel who are looking to understand better what the ALS is, along with the strengths, weaknesses and limitations of OECD guidance on TP.
Reviews
Subjects
- Taxation
- Cost Control
- Taxation Law
- Project
- Tax
- Profit
- Transfer Pricing
- Price
- OECD
- BEPS
- Model Tax Convention
- Transactional Margin
- Cost-sharing
Teachers and trainers (1)
Ian Wood
Teacher
Ian worked in a variety of transfer pricing roles for HMRC’s Business International unit (and its precursors) over a period of over 20 years – working variously as a transfer pricing analyst, team leader, manager, sector specialist, delegated Competent Authority and, from 2000-2012, the co-ordinator of the UK’s Advance Pricing Agreement programme. He is well known as a speaker at transfer pricing consultant to a top Accounting Firm.
Course programme
- Article 9 of the OECD Model Tax Convention – the ALS defined
- UK specific legislation: control, UK-to-UK situations, exceptions and exemptions, balancing payments
- Introduction to Ch. 1 of the OECD Transfer Pricing Guidelines – the presumptions behind (and weaknesses of) the OECD’s approach
- Comparability
- Functional analysis
- Identifying the ‘tested party’
- Methodologies – comparable uncontrolled prices, resale minus, cost-plus, the transactional net margin method and profit splits
- Cost-sharing arrangements
- ‘Principal’ structures and what has driven the BEPS project
- Areas where TP controversy is most likely
A Practical Guide to Transfer Pricing