Transfer Pricing (TP)
Distance Learning Course on Business Restructuring and Valuation, TP Legislation and Guidelines, and other hot topics
How to deal with international TP risk?
TP
has drawn the attention of tax authorities worldwide. New rules,
documentation requirements and different interpretation given to the
OECD TP guidelines by both tax authorities and multinationals have
created ground for many disputes.
International Management Forum (IMF) is happy to announce a new distance learning course on Transfer Pricing. This course will focus on major TP issues and concerns that all professionals involved in the complex area of TP will face such as: Business Restructuring and Valuation, TP Legislation and Guidelines, Documentation Requirements per region and per country, TP Project and Risk management, TP (pre) Controversy Management, Design and Development of a TP Policy, types of Intercompany Transactions, Intellectual Property, Customs.
Target group
This new toplevel distance learning course has been
designed to provide in depth training for financial, tax and TP
professionals who are interested in expanding their knowledge of the
theory and practice of TP.
The
course is relevant for TP managers, (inter)national tax managers and
firms, finance directors, treasurers, senior executives with an
interest in the latest developments in TP and lawyers and accountants
who serve their clients with TP issues and have to guide them in the
ever-changing TP environment.
Note! Salary Surveys among accountants, lawyers and economists reveil that practitioners with advanced transfer pricing knowlegde often earn more than twice as much as their counterparts with equivalent education and experience who lack transfer pricing expertise.
Continuing Professional Education (CPE)
It should be noted that this course may qualify for CPE credits pursuant to the rules of a number of professional associations. Participants are encouraged to check with their professional association to determine eligibility in this respect.
Voor
leden van de Nederlandse Federatie van Belastingadviseurs (NFB) levert
de cursus 5 studiepunten op in het kader van de verplichte Permanente
Educatie.
Deze cursus kan van
belang zijn voor de dagelijkse beroepsuitoefening van een
registercontroller. In dat geval kan de cursus in aanmerking komen voor
PE-punten. Raadpleeg hiervoor de regelgeving van de Vereniging van
Registercontrollers.
Sponsorship Opportunities
Increase your organisation’s profile to key industry professionals. Position yourself in front of potential clients to showcase your services. To learn more about sponsorship and other opportunities, please contact us.
Introduction
- Content of this course
- The context of the transfer pricing process
- Documentation requirements: Legal aspects per region
- Documentation requirements: Legal aspects per country
- Transfer pricing project and risk management
- Design and development of a Transfer Pricing Policy
- Transfer pricing (pre)-controversy management
LESSON II
Regulatory context: Transfer Pricing
- Introduction
- The OECD Transfer Pricing guidelines
- Application and authority of the Guidelines
- The Arm’s length principle
- Internal comparables
- External Comparables
- Factors determining comparability
- Contractual arrangements
- Economic circumstances
- Business strategies
- Other factors
- Introduction to transfer Pricing methods
- Transfer pricing methods
- Arm’s length principle
- Benchmarks and related economic aspects
LESSON III
Legislation and guidelines: Regional and country specific
LESSON IV
Design, development and implementation
LESSON V
TP Documentation in practice
LESSON VI
Controversy
- Audits
- Going to court
- Alternate dispute resolution (including APA, MAP and Arbitration)
LESSON VII
Transfer Pricing Project and Risk Management
LESSON VIII
Special File: Types of Intercompany Transactions
LESSON IX
Special File: Intellectual Property
LESSON X
Special File: Business Restructering and Valuation
LESSON XI
Special File: Customs
Transfer Pricing Associates (TPA) is the leading independent provider of global TP services and is part of the TPA Global group. TPA has offices and coverage in over 25 countries around the world and has an extensive practical knowledge and experience in a broad range of TP issues.
The authors from TPA are:
Peter AndersenPeter Andersen is Global Partner of TPA-Global and a part-time lecturer in International Transfer Pricing at the University of Copenhagen in Denmark. Peter holds a master degree in law from universities in Denmark and the United Kingdom, with specialization in (international) tax law.
Steef HuibregtseSteef Huibregtse is the Founding Member of TPA. He is a member of the Business Advisory Group to the OECD’s Joint Working Group on Business Restructuring. Steef developed a Global Transfer Pricing Risk Management tool and developed a Global Benchmark Platform and was involved in more than 1.000 regional an global transfer pricing studies.
Flor RamirezFlor Ramirez has a proven track record in Transfer Pricing projects in South America in service, retail, distribution, chemical, food and oil & gas. She advices multinationals in Europe and South America on the preparation of efficient ‘Master File’ Transfer Pricing documentation – such as regional management charges. Flor provides, amongst many other things guidance with the implementation of Transfer Pricing strategies within the dynamics of a multinational.
Roderick VeldhuizenRoderick is a Senior Manager at TPA and is part of the Gobal Valuation Practice. He has experience in performing valuations of companies and (intangible) assets.
Caterina RussoCaterina Russo is a Senior Project Manager of TPA and is located in the London Office. Caterina has Transfer Pricing experience throughout Europe. She speaks fluent Italian (native speaker), English and Spanish.
Louan VerdonerLouan Verdoner is Off Counsel at TPA and worked before at Solvay as the Head of Fiscal Department.
Enrico de AngelisBefore joining TPA Enrico de Angelis worked as an independent adviser to a leading association of importers in the recent high-profile EU antidumping case (expiry review) on imports of footwear originating in China and Vietnam. He also worked as a Senior Associate in the Trade & Customs Practice of KPMG.
Personal assistance
Should you have any questions about the lessons, please feel free to contact the authors of TPA.