A Practical Guide to Transfer Pricing

Course

In City of London

£ 545 + VAT

Description

  • Type

    Workshop

  • Location

    City of london

  • Class hours

    6h

  • Duration

    1 Day

  • Start date

    Different dates available

An "everyman's guide" to transfer pricing

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

City of London (London)
See map
138-142 Holborn, EC1N 2NQ

Start date

Different dates availableEnrolment now open
Different dates availableEnrolment now open

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.

Questions & Answers

Add your question

Our advisors and other users will be able to reply to you

Who would you like to address this question to?

Fill in your details to get a reply

We will only publish your name and question

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

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

£ 545 + VAT