06 - 10 Dec 2020Tax Planning and Transfer Pricing Advanced Bootcamp
- Tax Planning and Transfer Pricing Advanced Bootcamp
Overview and Learning ObjectivesThe course will focus on how to utilize the remaining tax planning opportunities and spot potential safe harbours following the implementation of the OECD/G20 BEPS Project, especially the new OECD Pillar One and Pillar Two solutions, the recently implemented and proposed EU direct tax initiatives and US tax reform, including:
Overview and Learning Objectives
- PE tax planning in light of the latest international case law
- ensuring beneficial ownership status for passive income in corporate structures
- successfully dealing with the impact of new EU/US anti-avoidance measures
- managing substance to dismantle anti-avoidance tools – how to get the right level of substance?
- setting up structures to effectively plan indirect transfers of real estate
- recent case law and domestic law developments concerning anti-abuse measures from around the globe (such as from China, India, Korea and many more countries).
In 2020, as in 2019 and 2018, transfer pricing (TP) remains a leading and challenging issue for tax and financial specialists of international companies and tax authorities. TP is at the centre of attention in an era of heightened tax risk and controversy, driven by an exponential increase in the demand for tax-related transparency. In addition, TP is the number one topic in tax audits around the world. More TP disputes are taking place in more jurisdictions than in the past. And, perhaps more significantly for the months and years to come, an expanding swathe of conflict spanning a wider range of geographies across a broader range of issues is expected. For this, both companies and tax authorities need to be prepared.
This three-day masterclass explores the TP issues confronting a multinational group that operates in a number of jurisdictions. Besides the OECD, UN and EU developments, also developments in the Middle East region are covered. Due to the OECD BEPS reports in the field of TP, which have catalysed country-level changes around the globe, the interest in TP has increased even more. The important new terms in the field of international taxation are substance and transparency, and these terms apply to TP as well.
The masterclass has been specially tailored to the practical needs of both tax authorities and tax, finance and TP professionals working in a variety of industrial and service sectors. Following a brief introduction to the individual topics, each session is complemented by a case study applying the principles in practice. All the sessions will cover guidance from international organizations and approaches taken by some tax authorities in the Middle East region.
The masterclass begins with a short and practical update on the latest OECD TP developments (Day 1), before it turns to a rolling case study on TP issues relating to the distribution, manufacturing, R&D, financing and management operations of the multinational group (Day 2 and Day 3). These are the most important areas of controversy for the coming years. The case study will ensure that the gap between theory and practice is bridged.
Field of Study
Who Should Attend?
The courses are suitable for tax managers and directors, accountants, legal, finance and other in-house specialists in commerce and industry, practitioners in tax advisory firms, as well as government officials with at least 5 years of experience and cross-border responsibilities.
Course Level and Prerequisites
These are advanced-level courses. Participants taking these courses will be expected to have a good understanding of international tax, tax planning and transfer pricing principles and practical challenges MNEs face during their daily operations.
- Managing Permanent Establishment Risks
- Ensuring Beneficial Ownership for Holding and Finance Companies.
- The Extraterritorial Reach of EU and US Tax Law – The Inbound and Outbound Perspectives
- The OECD Pillar One and Pillar Two Solutions: Redesign of International Taxation
- Tax Optimization of Cross-Border Real Estate Investment Gains
- Cross-Border Intra-Group Holding, Financing and IP Structures in a Post-BEPS Environment
- Lessons To Be Learned from Selected Tax Treaty Court Decisions
- Case Study-Based Assignment
- Transfer Pricing Post-BEPS
- Workshop Transfer Pricing and Digitalization
- OECD Discussion Draft on TP Aspects of Financial Transactions
- New OECD Project to Revise the Guidance in Chapter VII of the OECD TP Guidelines, “Special Considerations for Intra-Group Services”
- Case Study Part 1 – Intra-Group Services
- Case Study Part 2 – Manufacturing and Distribution Activities
- Case Study Part 3 – Financial Activities
- Case Study Part 4 – R&D Activities and IP Ownership