28 - 29 May 2020Transfer Pricing and Intra-Group Financing
- Transfer Pricing and Intra-Group Financing
Overview and learning objectives
This course addresses transfer pricing issues related to intra-group financing transactions. On 11 February 2020, the OECD released its final report with transfer pricing guidance on financial transactions. Over the last couple of years, countries have implemented more detailed transfer pricing legislation and guidance, while companies have tried to ensure that their cross-border intra-group product flows, royalties and management charges are set on an arm’s length basis and are fully documented. Unfortunately, the same cannot always be said for intra-group financing and the provision of treasury services. These issues are, however, of the utmost importance given that (i) the OECD issued its transfer pricing guidance on financial transactions, (ii) intra-group financing arrangements now form a key part in the transfer pricing Master File in the 2017 OECD Transfer Pricing Guidelines, and (iii) changes at the UN and EU level are also to be taken into consideration. In light of the increase in information transparency, these arrangements now need to be properly supported and documented. Currently, tax authorities are focusing on the application of the arm’s length principle to these transactions and growing awareness in this respect is to be expected.
This course provides participants with the confidence and practical understanding they need in the field of transfer pricing and intra-group financing. The course is aimed at giving participants insight into and deepening their knowledge of, for example, changes in market circumstances, setting up an efficient treasury function, the latest developments with respect to the OECD guidance, hybrid financing, guarantees and cash pooling. Although the course will deal with real-life cases, domestic legislation will not be addressed in specific detail.
Field of study
Who should attend?
The course is suitable for transfer pricing advisers, lawyers, accountants, tax inspectors, in-house tax and transfer pricing managers and directors and treasury managers.
Course level and prerequisites
This is an intermediate-level course. Participants taking this course will be expected to have a good understanding of transfer pricing principles.
Interactive course - "Group Live"
To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 32 participants will be accepted. Early registration is therefore recommended.
Continuing Professional Education
Recommended NASBA CPE points for this course: 13.5 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for IBFD International Tax Courses.
Course fee and registration details
The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.
- Transfer pricing and intra-group finance: an area of growing controversy
- Treasury function within an MNE
- Intercompany loans
- Cash pooling
- Case study