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 the global profits of multinational groups and to challenge aggressive tax planning structures that are not supported by sufficient substance. 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 the concerns of tax administrations reflected in recent transfer pricing cases? Which areas of intragroup pricing arrangements are the subject of most scrutiny in recent years? What can we learn from these cases that would help better understand the transfer pricing risks and how to manage them?
Block 1: Post-BEPS transfer pricing landscape
- Post-BEPS OECD Guidelines and remuneration spectrum
Block 2: Recent transfer pricing cases
- "Delineation" of intra-group transactions
- Comparability and 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
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.
- Sharvari Kale, IBFD, The Netherlands (to be confirmed)
- Monique van Herksen, Trafigura, The Netherlands
- Shee Boon Law, Consultant, International Tax and Transfer Pricing, IBFD, The Netherlands
- 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.
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.
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Field of study: Taxes
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.
