Financial Skills: Tax: Tax Effective Transfer Pricing

Course Code: CM025429      Days: 1
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Central London
City
London (WC1) 02/12/08 £ 560
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Course Overview

This course is aimed at those who already have a working knowledge of transfer pricing and who want to develop their knowledge further to understand how their transfer pricing can become more tax effective. A prior knowledge of topics covered in Fundamentals of Transfer Pricing is assumed.

Audience

Tax professionals and finance managers and those who are responsible for setting transfer pricing within a group of companies. As a result of attending participants should be able to identify planning opportunities offered by transfer pricing. Additionally they will learn about a proactive approach to dealing with transfer pricing investigations.

Course Outline

  • A review of the legislation and OECD framework to transfer pricing
  • How to develop a transfer pricing policy
  • How to make business change tax effective
  • Toll and contract manufacturing
  • Commissionaires and limited risk distribution structures
  • Intellectual property planning in the context of transfer pricing
  • Tax effective dispute resolution mechanisms
  • Permanent establishments and the latest OECD guidance on the topic
  • Exit charges in the context of business change
  • The impact of CFC legislation in the context of business change
  • Effective dispute resolution mechanisms


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