Taxation that is based on transfer pricing is becoming an important issue for many companies, whether U.S. based or foreign based. The regulations have sought to impose extensive general principles and guidelines that apply when the taxpayer selects the transfer pricing method. These methods impose penalties on an inappropriate choice of a transfer pricing method.
The goal of this Principles of International Transfer Pricing training course is to improve the fundamental knowledge of tax, accounting, and finance professionals on the main ideas and principles of transfer pricing. Additionally, it seeks to introduce the relationship between transfer pricing and more general technical tax, financial, and accounting sectors.
This training course will feature:
Separate-entity approach
The arm’s length principle
The Cost-plus method
The Transactional net margin method (TNMM)
The Profit split method (PSM)
Quais são os objectivos?
By the end of this training course, participants will be able to:
Improve the basic technical knowledge of transfer pricing and the significance of the arm's length principal
Develop a holistic understanding of the important elements and stages of a typical transfer pricing analysis
Analyze and develop an understanding of Domestic tax base erosion and profit shifting (DEPS) debate
Understand the transfer pricing legislative framework
Be advised of the recent developments and trends in the area of transfer pricing
A quem se destina este curso de formação?
This training course will not only be of benefit to planning team members, but it will also provide useful insights and tools for other professionals in related fields, in particular, the course will greatly benefit:
Financial accounting team members
Cost and management accounting staff
Finance managers
Budget managers
Commercial managers
Capital investment and project team members
Investment analysts and acquisition team members
Risk managers
Descrição do curso
Day One: Introduction to Transfer Pricing
Separate-entity approach
What is transfer pricing?
The significance of intra-group relations
The importance of transfer pricing to states
The importance of transfer pricing to MNE Groups
Day Two: The Legal Framework
The international tax environment
The arm’s length principle
The alternative to the arm’s length principle: a global formulary apportionment
The features of domestic transfer pricing regimes
The importance of tax treaties (OECD and UN Models- Art. 9 and 25)
The importance of the OECD Transfer Pricing Guidelines
Day Three: Transfer Pricing Methods
The Comparable uncontrolled price (CUP) method
The Resale price method (RPM)
The Cost-plus method
The Transactional net margin method (TNMM)
The Profit split method (PSM)
The Commodity rule
Day Four: Transfer Pricing Adjustments
Compensating adjustments
Primary adjustments
Corresponding adjustments
Secondary adjustments
Repatriation
Day Five: Transfer Pricing Documentation
Purpose of transfer pricing documentation
Domestic transfer pricing documentation rules
OECD Guidance (OECD Transfer Pricing Guidelines: Chapter V)
Compliance issues
United Nations Guidance
Case studies and examples
O certificado
Coventry Academy Certificate of Completion for delegates who attend and complete the training course