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15 - 17 Apr 2020Principles of Transfer Pricing

The OECD, EU and UN have been and are still implementing guidance related to base erosion and profit shifting (BEPS), and many of these developments affect transfer pricing.
This course will therefore address the international frameworks that are in place, the legislation/guidance that is in place, and approach that is taken by tax authorities in several jurisdictions in the Asia-Pacific region.
 
Type:
Tax Courses
Language:
English
Location:
Kuala Lumpur - Malaysia
Level:
Introductory
Course code:
OC20PTP2
Price:
EUR 1,300 / USD 1,560 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Early Bird Discount: a 30% discount will be applied automatically to registrations received until 15 February 2020.
Principles of Transfer Pricing
Overview and Learning Objectives
The OECD, EU and UN have been and are still implementing guidance related to base erosion and profit shifting (BEPS), and many of these developments affect transfer pricing. Many countries in the Asia-Pacific region (e.g. India, Indonesia, Vietnam, Malaysia and Thailand) have partially or fully implemented into their legislation the three-tiered standardized OECD approach to transfer pricing (TP) documentation or are planning to do so. In addition, tax authorities across the Asia-Pacific region are or have been reviewing their current rules and audit frameworks to consider and implement concepts around “substance” and “value creation”, in line with the guidance contained in Actions 8-10 of the OECD BEPS project. With the increased focus on BEPS, many companies today face transfer pricing disputes in more countries than one. The aforementioned developments require a different approach from both tax authorities and multinational enterprises towards transfer pricing. Each session of this course will therefore address the international frameworks that are in place, the legislation/guidance that is in place, and approach that is taken by tax authorities in several jurisdictions in the Asia-Pacific region.
 
This course consists of theoretical sessions which are complemented by case studies and examples. The objective of this course is to understand the key aspects of transfer pricing. Upon completion of the course, participants will be able to:
- Assess potential transfer pricing risks as well as potential transfer pricing opportunities;
- Explain the most recent transfer pricing developments; -
- Find comparables, understand the different comparability factors and determine which comparability adjustments can be made; 
- Determine an arm’s length price for various intra-group transactions;
- Name the different elements of a CbC report, Master File and Local File;
- Apply in practice the examples analysed during the training.

This course serves as good preparation for the CIOT’s ADIT Paper 3.03. For more information about the Advanced Diploma in International Taxation, see the CIOT’s website.
 
This is an interactive course with a maximum of 40 participants. Participants will receive access to online supplementary materials.
 
Who Should Attend?
The course is targeted at finance and tax personnel of multinational enterprises, tax accountants, economists and lawyers, in-house tax managers, tax and transfer pricing advisers, and government officials and tax officers.

Course Level and Prerequisites
This is an introductory-level course. Whilst prior experience of transfer pricing is desirable, it is not a prerequisite in order to satisfactorily participate in this course. There will be ample opportunity for the audience to ask questions, participate in group discussions and to network.
  • Introduction to Transfer Pricing
  • Comparability Analysis
  • Transfer Pricing Methods
  • Transfer Pricing and Intangibles
  • Global Supply Chain Considerations and Business Restructuring
  • Intra-Group Services
  • Intra-Group Finance Transactions
  • Documentation
  • Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
  •  
    Anuschka Bakker is the Manager of the Transfer Pricing and Specialist Knowledge Group of IBFD in Amsterdam. In addition, she acts as the Cluster Manager for the transfer pricing courses offered by...
  • Subhabrata Dasgupta (Subho) is a partner in the transfer pricing service line of Deloitte Malaysia. He has extensive experience in working with Deloitte network offices in Asia, the EMEA and the...
  • Gita V. Sheth is currently employed as Assistant Vice President – Tax with CIMB Bank, a global banking group headquartered in Malaysia and having operations in more than 20 countries with...