Transfer Pricing Module 2 - Planning & Control

Overview

Gain an understanding of advanced transfer pricing issues and how to deal with them including how to:

• Integrate transfer pricing into business and tax strategies
• perform the required transfer pricing analyses
• select and implement appropriate transfer pricing policies
• identify practical issues in business restructurings
• know which evidence needs to be gathered
• identify and manage transfer pricing risk
• operate internal controls to manage transfer pricing risk
• manage the audit and defence process
• manage risk of double taxation.

Who is this for?

• Financial directors and controllers with some knowledge of transfer pricing needing an appreciation of the operational risk and strategic opportunities.
• Tax specialists seeking an understanding of the advanced elements of transfer pricing.

Delegates attending this course should either have attended Transfer Pricing Module 1 - Fundamentals or have a good grasp of basic transfer pricing concepts. Delegates may also be interested in the follow-on module Transfer Pricing Module 3 - Operational Effectiveness

What will you learn?

• Comparability factors.
• Business restructuring.
• PE existence.
• PE profit.
• Intangibles and IP.
• ‘Interesting countries’.
• Thin Cap.
• Running an in-house transfer pricing function.
• Common snags and mistakes: how to avoid them.
• To APA or not to APA?
• Planning and tax strategy.
• Transfer pricing the treasury function.

Other related courses

Transfer Pricing Module 1 – Fundamentals

Transfer Pricing Module 3 - Operational Effectiveness