Transfer Pricing

IMF Academy

Course

Distance

Price on request

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Description

  • Type

    Course

  • Level

    Advanced

  • Methodology

    Distance Learning

  • Duration

    11 Weeks

  • Start date

    Different dates available

The global Transfer Pricing landscape is fraught with uncertainty and complexity. Transfer Pricing has drawn the attention of tax authorities and taxpayers worldwide. New rules, documentation requirements and different interpretation given to the OECD Transfer Pricing Guidelines by both tax authorities and multinationals have created ground for many disputes.

A significant Transfer Pricing issue facing multinational enterprises (MNEs) is Base Erosion and Profit Shifting (BEPS). On October 5, 2015, the OECD released the final BEPS reports to address perceived gaps in the international tax and transfer pricing rules in order to eliminate so-called ‘double non-taxation’ as well as no or low taxation, associated with practices that are perceived to segregate taxable income from the activities that generate them. The existing OECD Transfer Pricing Guidelines (TPG) are changing and policies that previously were compliant may need to be reviewed and in some cases, changes to the pricing made. It is now time for multinational enterprises to determine what practical implications they face and how they can best operate within this radically changed regulatory environment.

Major Transfer Pricing issues and concerns
This Transfer Pricing course will focus on major Transfer Pricing issues and concerns that all professionals involved in the complex area of Transfer Pricing will face such as: Business Restructuring and Valuation, Transfer Pricing Legislation and Guidelines, Documentation Requirements per region and per country, Transfer Pricing Project and Risk management, Transfer Pricing (pre-) Controversy Management, Design and Development of a Transfer Pricing Policy, types of Intercompany Transactions, Intellectual Property, Customs and, of course, the implications of BEPS for Transfer Pricing.

Facilities

Location

Start date

Distance Learning

Start date

Different dates availableEnrolment now open

About this course

This toplevel distance learning course on Transfer Pricing was designed to provide in-depth training for financial, tax and Transfer Pricing professionals who are interested in expanding their knowledge of the theory and practice of Transfer Pricing.

The course is relevant for Transfer Pricing managers, (inter)national tax managers and firms, finance directors, treasurers, senior executives with an interest in the latest developments in Transfer Pricing, and lawyers and accountants who serve their clients with Transfer Pricing issues and have to guide them in the ever-changing Transfer Pricing environment, and many other professionals.

Note! Salary surveys among accountants, lawyers and economists reveal that practitioners with advanced Transfer Pricing knowledgee often earn more than twice as much as their counterparts with equivalent education and experience who lack Transfer Pricing expertise.

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Subjects

  • IT Management
  • Management
  • Transactions
  • Customs
  • Project
  • Risk
  • IT risk
  • Tax
  • Project Risk
  • Design
  • Project Risk management
  • Risk Management
  • Intellectual Property
  • Audit
  • IT
  • Transfer Pricing

Teachers and trainers (4)

Enrico de Angelis

Enrico de Angelis

Joining TPA

Before joining TPA Enrico de Angelis worked as an independent adviser to a leading association of importers in the recent high-profile EU antidumping case (expiry review) on imports of footwear originating in China and Vietnam. He also worked as a Senior Associate in the Trade & Customs Practice of KPMG.

International Management Forum IMF

International Management Forum IMF

publisher of distance learning courses and organizer

Rudolf Sinx

Rudolf Sinx

Partner of Transfer Pricing Associates

Rudolf Sinx is partner of Transfer Pricing Associates and has over 20 years of experience in many industries with extensive exposure to transfer pricing. Before joining TPA, Rudolf was partner and head of the transfer pricing team at Mazars, and key member of the transfer pricing team at Loyens & Loeff. He is a member of the International Fiscal Association and author of the International Transfer Pricing Journal.

Steef Huibregtse

Steef Huibregtse

Founding Member of TPA

Steef Huibregtse is the Founding Member of TPA. He is a member of the Business Advisory Group to the OECD’s Joint Working Group on Business Restructuring. Steef developed a Global Transfer Pricing Risk Management tool and developed a Global Benchmark Platform and was involved in more than 1.000 regional an global transfer pricing studies.

Course programme

LESSON I
Transfer Pricing – introduction

  • Context of the Transfer Pricing process
  • Basic principles and terminology, methodologies

LESSON II
Documentation requirements in the regulatory context of Transfer Pricing

  • OECD Transfer Pricing Guidelines
  • Factors determining comparability
  • Introduction to and application of Transfer Pricing methods: Comparable Uncontrolled Price (CUP) method, Resale Price Method (RPM), Cost Plus Method (CPM), Transactional Profit Split Method (TPSM), Transactional Net Margin Method (TNMM)

LESSON III
Transfer Pricing legislation and guidelines

  • Advanced Pricing Agreements (APA)
  • US: the country of origin
  • OECD: setting a global standard
  • Europe
  • Australia
  • Asia
  • Latin America
  • Trends in national, regional and global documentation standards

LESSON IV
Transfer Pricing policy – design and implementation

  • Transfer Pricing process
  • Designing examples for goods, services and intangibles
  • Manual: how to design your Transfer Pricing system
  • Checklist for taxpayers

LESSON V
Transfer Pricing documentation – practical aspects

  • Transfer Pricing documentation rules
  • Centralized documentation, local documentation, hybrid approach, other documentation issues
  • G20/OECD BEPS Action 13
  • Use of the master file in practice
  • Use of country-specific files in practice (autonomous and complementary approach)
  • Best practices of Transfer Pricing documentation

LESSON VI
Transfer Pricing (pre-)controversy management

  • Connectivity between 4 boxes
  • Audit procedures
  • Advance Pricing Agreements (APA)
  • Mutual Agreement Procedure (MAP)
  • EU Arbitration Convention
  • Penalties and interest charges
  • Pre-controversy management tools
  • Case examples

LESSON VII
Transfer Pricing project and risk management

  • Transfer Pricing process
  • From Transfer Pricing risks to tax provision
  • Practical considerations for a Transfer Pricing project
  • Transfer Pricing documentation and risk assessment

LESSON VIII
Types of inter-company transactions

  • List and examples of the most common inter-company transactions
  • List and examples of more complex inter-company transactions
  • Toolbox for analysis

LESSON IX
Transfer Pricing of intangibles

  • The context of Transfer Pricing of intangibles
  • Labelling of intangibles
  • Identification of intangibles
  • Ownership of intangibles (legal or economic)
  • Valuation of intangibles
  • Examples: valuation of customer list and valuation of content-related intangibles

LESSON X
Business restructuring (BR) and valuation

  • Definition of business restructuring
  • Country-specific considerations
  • Analysis of the situation before versus after business restructuring
  • Valuation aspects of a business restructuring
  • Case Study

LESSON XI
Transfer Pricing and customs

  • Differences and similarities between the 2 sets of rules
  • International debate on the harmonization of Transfer Pricing and customs valuation
  • Price and profit adjustments: alignment procedures in the US and the EU

See related categories

Transfer Pricing

Price on request

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