Transfer Pricing and Business Restructuring

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The Transfer Pricing and Business Restructuring course provides a practical guide to the transfer pricing aspects of business restructurings for taxpayers as well as tax authorities. This course includes techniques for use in developing or assessing the transfer pricing implications of any changes to the structure and activities of corporations.

Topics Covered

  • Business models and digital transformation
  • Importance of business restructurings – tax perspective
  • Recognition of business restructuring
  • Arm’s length consideration for restructuring
  • Conversion issues and post restructuring issues
  • Selected Issues in global value chain analyses
  • Business restructurings and indirect taxes

Learning Objectives

Skills practiced and developed during the course include:

  • Identify the drivers for business model transformation and the role of data
  • Define the common types of business restructurings and the related policy framework
  • Identify the important considerations in the accurate delineation and non-recognition of business restructurings
  • Apply the various concepts such as options realistically available and commercial rational behavior in relation to business restructurings
  • Apply the four-step approach for determining an arm’s length compensation for the transfer of “value” in a restructuring
  • Identify the tax accounting considerations and reporting issues related to the business restructurings
  • Assess the impact of business restructuring from a VAT and customs perspective

Who Should Participate

The course is open for all; however, it would be highly beneficial for:

  • Tax lawyers from law/and or accounting firms
  • Tax/TP managers of law/accounting firms
  • Tax/TP managers/directors of MNEs
  • Finance manager/controllers/treasury managers of MNEs
  • Tax inspectors from tax administrations

Recommended prerequisites (for guidance only) and advance preparation

No advance preparation is necessary. All required study material is provided within the online training.

Total Study Time and Access Period

Access to the online course is granted for a period of 2 months, from the date of ordering or the indicated start date.

Mandatory course activities: 10 hours 28 min

All mandatory course activities can be completed within the access period by dedicating approx. 1 hours 15 mins of study per week. Please note that study materials included in the course or certificate programme will be accessible for the duration of the access period only. Non-mandatory supplementary material is also provided in this course.

Continuing Professional Education (CPE)

We recommend you check with your respective accrediting organizations to determine the eligibility of CPE credits.

International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Recommended NASBA CPE credits for this course is: 13

FAQ

See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or contact us at info@ibfd.org

Additional Information

Field of study: Taxes

Delivery format: Online - QAS Self Study

Course Last Review : This course was last reviewed in July 2023

Disclaimer

Please note that the content of this online course is subject to change based on updates in industry standards, regulatory requirements, and other developments. We strive to provide the most accurate and current information; however, we recommend verifying any critical details independently.