Transfer Pricing
Gain an understanding of basic transfer pricing issues and how to deal with them and onto more complex subjects of transfer pricing such as Comparability factors, Business restructuring, PE existence, PE profit Intangibles and Running an in-house transfer pricing function.
Overview
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- Face-to-Face from £882.00All courses Inc VAT and excludes exams
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Transfer Pricing papers
Transfer Pricing Module 2 - Planning & Control
Gain an understanding of advanced transfer pricing issues and how to deal with them including how to: Integrate transfer pricing into business and tax strategies perform the required transfer pricing analyses select and implement appropriate transfer pricing policies identify practical issues in business restructurings know which evidence needs to be gathered identify and manage transfer pricing risk operate internal controls to manage transfer pricing risk manage the audit and defence process manage risk of double taxation.- No extra learning materials
Course structure
Gain an understanding of basic transfer pricing issues and how to deal with them including how to:
perform the required analyses select and implement appropriate transfer pricing policies
know which evidence needs to be gathered
identify and manage transfer pricing risk
manage the audit and defence process
All needing an incisive insight into the mechanics of transfer pricing, including management and financial accountants, operational managers, financial managers and their junior tax staff in large and medium sized groups in all sectors.
What is transfer pricing?
Corporate objectives
Transfer pricing methods
Functional analysis
Economic analysis and comparability studies
Intra-group services and HO expenses
Cost sharing and cost contribution arrangements
Documentation
Transfer pricing governance and control
Adjustments and dispute settlements
Audits and how to manage them
Risk management
Looking to the future
Course structure
Gain an understanding of advanced transfer pricing issues and how to deal with them including how to:
Integrate transfer pricing into business and tax strategies
perform the required transfer pricing analyses select and implement appropriate transfer pricing policies
identify practical issues in business restructurings know which evidence needs to be gathered
identify and manage transfer pricing risk
operate internal controls to manage transfer pricing risk manage the audit and defence process
manage risk of double taxation
Financial directors and controllers with some knowledge of transfer pricing needing an appreciation of the operational risk and strategic opportunities
Tax specialists seeking an understanding of the advanced elements of transfer pricing
Delegates attending this course should either have attended Transfer Pricing Module 1 - Fundamentals or have a good grasp of basic transfer pricing concepts.
Delegates may also be interested in the follow-on module Transfer Pricing Module 3 - Operational Effectiveness
Comparability factors, Business restructuring, PE existence, PE profitIntangibles, Running an in-house transfer pricing function
Common snags and mistakes: how to avoid them
To APA or not to APA?
Planning and tax strategy
Transfer pricing the treasury function
Course structure
Transfer pricing is heavily fact dependant - once you have set the pen down on your report it will become progressively out of date as the operations of the company evolve.
The good practices that you may have instilled during a transfer pricing project may also be eroded with the passage of term and the emergence of different and conflicting priorities.
This third module brings together the knowledge that participants should have acquired in the first two courses on principles and documentation. It looks at the practical aspects of maintaining good defences against tax authorities probes on transfer pricing.
This course is designed to follow on from Transfer Pricing Module 1 – Fundamentals and Transfer Pricing Module 2- Planning & Control. Although it is not a prerequisite to have attended either module 1 or 2 before attending module 3, delegates should ensure they have equivalent knowledge before attending module 3.
The course is designed for Tax Professionals working in-house who need to deal with transfer pricing but also for advisers seeking to understand the dynamics of a transfer pricing team.
This very practical course includes: -
How to manage a transfer pricing team.
How to deal with other stakeholders in the company.
The controls that are required to ensure that the transfer pricing policies are in practise adhered to.
The third module will also deal with the recent changes in requirements as a result of OECD recommendations. The course will also look at the changes to transfer pricing which are likely to occur as a result of the Covid emergency.
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