Transfer pricing disputes and recent cases

Transfer pricing disputes have consistently been the most pressing issues for multinational groups in the post-BEPS era, as countries look to gain a "fairer" share of global profits by challenging their intragroup pricing arrangements. At the same time, the updated OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations have provided countries with more tools that can be applied to ensure intra-group transfer pricing arrangements conform with the arm's length principle. How are these concerns and developments reflected in recent transfer pricing cases? What can we learn from these cases that would help better understand the transfer pricing risks and how to manage them?

Topics Covered

Block 1: Post-BEPS transfer pricing landscape

  • Post-BEPS OECD Guidelines and remuneration spectrum 

Block 2: Transfer pricing cases

  • Non-recognition and "Delineation" of intra-group transactions 
  • Transfer pricing methods
  • Business restructuring transactions

Block 3: Practical impact of recent transfer pricing cases

  • Concluding remarks on the impact of recent transfer pricing cases

Learning Objectives

After this webinar, the participants will be able to: 

  • Differentiate the causes of transfer pricing disputes in key recent cases;
  • Identify the key principles established by these cases in addressing transfer pricing disputes;
  • Compare and contrast the positions taken by different parties to the dispute; and
  • Assess the practical impact of the decisions of key recent cases.

Instructors

  • Gaspar Lopes Dias, Tax Partner, Taxand
  • Demis Ioannou, Tax Partner, Taxand
  • Costas Savva, Tax Partner, Taxand Cyprus
  • Christos Theophilou, International Tax and Transfer Pricing Director, Taxand Cyprus

Field of study

Taxes
 

Who should participate

  • In-house tax professionals and advisors looking to understand the impact of recent transfer pricing cases on the transfer pricing arrangements of multinational groups.
  • Legal professionals assessing the risks of transfer pricing arrangements and how best to mitigate such risks. 
  • Government officials engaging in monitoring and controlling the compliance activities of multinational groups, as well as those involved in auditing their transfer pricing arrangements. 

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and be familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 25 July 2023

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE on the National Registry of CPE Sponsors. State boards of accountancy have the 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. NASBA CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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