08 - 10 Apr 2019Transfer Pricing and Substance Masterclass
- Transfer Pricing and Substance Masterclass
Overview and Learning Objectives
The OECD BEPS Project and the 2017 OECD Transfer Pricing Guidelines focus on two items: substance and transparency. This is reflected in the guidelines published by the OECD on, inter alia, services, intangibles, intra-group financing and country-by-country (CbC) reporting. The consequences of the BEPS reports entail changes for day-to-day business operations. Businesses have already taken action (in some cases, urgent action) both to comply with new requirements and to consider the ways in which they do business in different countries. Monitoring and taking additional actions is needed in the following years. This masterclass addresses questions such as how value creation translates into a price or transfer pricing (TP) methodology, how to approach a value chain analysis, how to get the information related to CbC reporting out of an organization and whether your organization is ready to meet the TP documentation requirements efficiently. Tax disputes are increasing in number. It is therefore essential to be aware of such disputes and to be prepared for resolving them in a methodical and timely manner. This will increase your chances of survival in tax disputes.
This advanced-level, interactive masterclass consists of case studies and sharing best practices. It is designed for participants who already have knowledge of TP and want to gain more in-depth understanding of the implications of BEPS in their day-to-day practice. Participants will receive a roadmap for the changes that each of the BEPS reports on TP brings and how these reports are interrelated.
The objective of the masterclass is not only to introduce the participants to changes resulting from the OECD BEPS reports but also to provide an understanding of the finer details pertaining to the practical implementation of the guidelines laid down in the BEPS reports. This will be done by means of case studies and sharing best practices focusing e.g. on specific transactions such as services, intra-group financing and intangibles. Following a brief introduction to the individual topics, each session is complemented by a case study applying the principles in practice.
To safeguard the interactive nature of the course, including group discussions, the number of particip-ants is limited. Early registration is therefore recommended. Participants will be given access to additional reading material and supplementary material (e.g. legal documentation, case law and related articles/literature).
Field of Study
Who Should Attend?
The course is suitable for transfer pricing advisers, lawyers, accountants, in-house transfer pricing managers, controllers and finance staff.Course Level and Prerequisites
This is an advanced-level course. Participants taking this course will be expected to have a good understanding of transfer pricing.
- Case study: applying arm’s length principle and transfer pricing methods
- Case study: intangibles
- Case study: services
- Case study: intra-group financing
- Case study: compliance
- Case study: dispute resolution