Transfer Pricing

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Covid-19 Impact on Transfer Pricing

This leading edge program is designed to understand the concept of Transfer Pricing in the context of meeting the regulatory requirements and achieving tax efficiency. This workshop is essential for organizations seeking to lay down an effective strategy for Transfer Pricing. Such a strategy can achieve tax efficiency; avoid needless disputes with tax authorities; and curtail litigation.

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Managers and Executives of Corporate Finance, Tax, Accounting, Company Law Compliance, Company Secretary. Case studies from all Sectors of Industry

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SESSION 1:

Transfer Pricing and when do Transfer Pricing Regulations Apply?

• The program begins right off with a case study to illustrate and examine when is Transfer Pricing triggered? And what is the Arm’s Length Principle? 
• Concept of Associated Enterprises
• International Transactions covered by Transfer Pricing Regulations
• Domestic Transfer Pricing – change in law from FY 2012-13, additional transactions covered by Transfer Pricing Regulations
• Case studies on the above topics

SESSION 2:

Documentation & Audit

• The prices of transactions between Associated Enterprises have to be at Arm’s Length – How to determine the Arm’s Length Price?
• Documentation – what to maintain, when to maintain, how to maintain?
• Transfer Pricing Audit – when and how to file the Audit Report?
• Penalties

SESSION 3:

Computing ARM’S LENGTH TRANSFER PRICE

• Six prescribed Transfer Pricing Methods to compute the Arm’s Length Price
• Practical examples on application of the six methods
• How to select the Most Appropriate Method?
• Benchmarking of intra-group services, transfer of goods, royalty, and interest payments

SESSION 4:

Economic Analysis / Benchmarking under TNMM (most popular method)

In the Times of Covid – 19

• Nine Step process recommended by OECD
• Functions, Assets and Risks (FAR) Analysis
• Selecting the Tested Party 
• Searching for comparables
• Relevant filters to select the final set comparables
• Selection of an appropriate Profit Level Indicator (PLI)
• Computation of PLI
• How to make the right economic adjustments to the PLI?

SESSION 5:

Transfer Pricing Assessment Trends- Recent Issues & Dispute Resolution Approaches

• Representing your case before the Transfer Pricing Officer
• How to defend your transfer prices before the Tax Authorities?
• Preparing for Transfer Pricing assessments, disputes and litigation
• The approach and thought process of the Tax Department
• Advance Pricing Agreements
• Safe Harbour Rules
• Mutual Agreement Procedure

SESSION 6:

OECD BEPS PROJECT:  The New Transfer Pricing Landscape.

• BEPS Action Plans (8-10 and 13) – DEMPE Concept of Intangibles, C-by-C Report and Master File
• Transfer Pricing Post-BEPS
• Practical Update on the latest OECD Transfer Pricing Developments
• Recent Landmark Judgements