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29 Sep - 03 Oct '19Tax Planning and Transfer Pricing Intermediate Bootcamp

The Tax Planning and Transfer Pricing Intermediate Bootcamp is a combination of the two courses held in Dubai 29 September - 3 October 2019:
 
This 2.5-day upper intermediate-level course concentrates on a number of common international tax planning scenarios in Africa and the Middle East (ME) region. It examines the widely used regional tax planning routes, structures and tax treaties. Attention will also be paid to domestic and regional tax policy and transfer pricing developments. 
 
In order to deal with all developments in the field of transfer pricing properly, it is essential to fully understand the transfer pricing principles and methodologies and their practical application. This 2.5-day intermediate-level course introduces participants to such principles and methodologies and then covers their application to specific categories of intra-group dealings. The theoretical sessions are complemented by case studies.
 
Type:
Tax Courses
Language:
English
Location:
Dubai - UAE
Level:
Intermediate
Course code:
OC19DUBCMB1
Price:
EUR 2,499 / USD 2,990 (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 automatically applied for registrations received 30 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
 
 
Tax Planning and Transfer Pricing Intermediate Bootcamp

 

Tax Planning in Africa and the Middle East

Overview and Learning Objectives
This 2.5-day upper intermediate-level course concentrates on a number of common international tax planning scenarios in Africa and the Middle East (ME) region. It examines the widely used regional tax planning routes, structures and tax treaties. Attention will also be paid to domestic and regional tax policy and transfer pricing developments. Regarding the ME region, special consideration will be given to certain domestic tax regimes, such as Bahrain, Egypt, Lebanon, Oman, Qatar and the United Arab Emirates. In addition, the course will take a specific look at different sub-Saharan countries in Southern Africa, Central Africa and East Africa and will provide a high-level overview of the specific features of the tax systems that make these countries lucrative investment targets in the region. Course participants will also learn about some other jurisdictions (e.g. the Netherlands, Luxembourg and Switzerland) that are commonly used as investment gateways to Africa.

The course covers, through a combination of formal presentations and complex examples, some common tax planning tools involving holdings, financing and treasury companies and branches, and tax consolidation regimes. Both inbound and outbound tax planning techniques will be examined. The course will present the latest issues for manufacturing and distributor multinational enterprises as well as an introduction to tax planning related to R&D activities, intangibles and permanent establishments, including the potential impact of recent international developments under the OECD Base Erosion and Profit Shifting (BEPS) Project and the Multilateral Instrument on tax planning in selected African and ME countries. The course also includes a session on global developments concerning the US tax reform, EU initiatives and the hot topic of digital economy, which might all have an impact on local businesses.
This course is designed to provide participants who deal with international tax planning in the region with updates on relevant tax treaty and transfer pricing developments. The course is also important for those tax professionals who are not based in Africa or the Middle East but whose day-to-day work requires further knowledge of the tax issues of the region.

After the course, participants will be given access to online supplementary materials (e.g. legal documentation, case law and related articles/literature).
 

Principles of Transfer Pricing

Overview and Learning Objectives
Transfer pricing deserves to be a top-of-mind priority. The OECD, United Nations, European Union and individual countries have changed and keep changing their guidance in the field of transfer pricing due to the BEPS Project. The new 2017 Transfer Pricing Guidelines (TPG) can be considered a game changer and are expected to alter the transfer pricing outcomes in many situations. This requires a different approach from both tax authorities and multinational enterprises. A significantly more granular risk and functional analysis should be performed. Companies as well as tax authorities need to have a better understanding of how value is created with respect to the development and exploitation of their intangibles. A further point of focus is the way in which companies and tax authorities should deal with the three-tiered OECD approach related to transfer pricing documentation.

In order to deal with all developments in the field of transfer pricing properly, it is essential to fully understand the transfer pricing principles and methodologies and their practical application. This 2.5-day intermediate-level course introduces participants to such principles and methodologies and then covers their application to specific categories of intra-group dealings. The theoretical sessions are complemented by case studies.

Following the course, participants will be given access to an online platform which provides them with additional reading material and supplementary material (e.g. legal documentation, case law and related articles/literature).
 
Field of Study
Taxes

Course Level and Prerequisites
This is an upper intermediate-level course. Participants taking this course will be expected to have a good understanding of at least one national tax system and the fundamentals of double tax treaties and transfer pricing.

 

  • Introduction to the Domestic Tax Systems in the ME Region
  • Tax Treaty Network of the ME Countries and the Impact of the OECD Multilateral Instrument
  • Introduction to the Domestic Tax Systems of Selected African Countries
  • Tax Treaty Network of Selected African Countries and the Impact of the OECD Multilateral Instrument
  • Current Issues Concerning Cross-border Tax Structures
  • Tax Planning for Holding Activities in the Middle East
  • Tax Planning for Financing and R&D Activities in the Middle East
  • Tax Planning for Holding and Financing Activities in Africa
  • Managing Permanent Establishment Risks in the Middle East and in selected African Countries
  • Introduction to transfer pricing
  • Transfer pricing methods
  • Comparability analysis
  • Intangibles and cost contribution arrangements
  • Intra-group service
  • Intra-group finance transactions
  • Business restructuring
  • Transfer pricing risk management
  • Case studies
  • Emily Muyaa
    Emily Muyaa is the Managing Principal for Sub-Saharan Africa in the IBFD Africa and Middle East Department. In this capacity, she oversees IBFD's product offering in the region. Ms. Muyaa...
  • Ridha Hamzaoui is the Regional Tax Manager for Africa and Middle East regions under the IBFD Africa, Middle East and Latin America Knowledge Group. He is an expert on tax law and tax treaties for...