UnscheduledTransfer Pricing and Substance Masterclass
- Transfer Pricing and Substance Masterclass
Overview and Learning Objectives
The OECD, European Union 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. Asia-Pacific countries have been – or are still – implementing similar rules in their own tax systems. In addition, the business models of multinational enterprises (MNEs) have been changing, and international organizations and tax authorities in different countries are trying to tax the profits made via these new, data-driven business models. Thus, from a risk management perspective, it is essential for MNEs to be fully aware of the different approaches that are taken by international organizations and various tax authorities with respect to substance, digitalization of the economy, intangibles, intra-group services, intra-group financing, permanent establishments, transfer pricing (TP) documentation and dispute resolution.
The consequences of the aforementioned developments 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 are needed in the following years. This masterclass addresses questions such as how value creation translates into a price or TP methodology, how to approach a value chain analysis, how to get the information related to country-by-country (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 a more in-depth understanding of the implications of changed TP and international tax concepts in their day-to-day practice.
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 Asia-Pacific region.
To safeguard the interactive nature of the course, including group discussions, the number of participants is limited. Early registration is therefore recommended. Participants will be given access to additional reading material and supplementary materials (e.g. legal documentation, case law and related articles/literature).
Field of Study
Taxes, Transfer Pricing
Who Should Attend?
The course is suitable for transfer pricing advisers, lawyers, accountants, in-house transfer pricing managers, controllers, finance staff and government officials and tax officers.
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. There will be ample opportunity for the audience to ask questions, to participate in group discussions and to network.
- Workshop Value Chain Analysis
- Workshop Transfer Pricing and Digitalization
- Case Study: Intangibles
- Case Study: Services
- Case Study: Intra-Group Financing
- Workshop: Allocation of Profits to Permanent Establishments
- Workshop: Compliance
- Case Study: Dispute Resolution