IMF Academy

      Transfer Pricing

      IMF Academy
      Fernunterricht

      Preis auf Anfrage

      Wichtige informationen

      Tipologie Kurs
      Methodologie Fernunterricht
      Dauer 11 Weeks
      Beginn nach Wahl
      • Kurs
      • Fernunterricht
      • Dauer:
        11 Weeks
      • Beginn:
        nach Wahl
      Beschreibung

      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.

      Wichtige informationen
      Ist dieser Kurs für mich?

      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.

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

      Einrichtungen (1)
      Wo und wann
      Beginn Lage
      nach Wahl
      Distance Learning
      Beginn nach Wahl
      Lage
      Distance Learning

      Was lernen Sie in diesem Kurs?

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

      Themenkreis

      LESSON I
      Transfer Pricing: Introduction

      • The context of the Transfer Pricing Process
      • Basic Principles and Terminology, Methodologies


      LESSON II
      Documentation Requirements in the regulatory context of Transfer Pricing

      • The OECD Transfer Pricing Guidelines
      • Factors determining Comparability
      • Introduction to Transfer Pricing Methods


      LESSON III
      Transfer Pricing Legislation and Guidelines

      • 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
      Design and Implementation of a Transfer Pricing Policy

      • The 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 – 3 concepts
      • Use of the Master File in practice
      • Use of country-specific Files in practice
      • 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
      • Pre-Controversy Management Tools
      • Case examples


      LESSON VII
      Transfer Pricing Project and Risk Management

      • Transfer Pricing Project Management
      • 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
      • Valuation of Intangibles
      • Examples


      LESSON X
      Business Restructuring and Valuation

      • Definition of Business Restructuring
      • Country-specific considerations
      • Analysis of the situation before versus after Business Restructuring
      • Valuation aspects of a Business Restructuring
      • OECD Guidelines Chapter IX
      • TR 2011/1
      • Case Study


      LESSON XI
      Transfer Pricing and Customs

      • Differences and similarities between the 2 sets of rules
      • The international debate on harmonization of Transfer Pricing and Customs Valuation
      • Price and Profit Adjustments