Transfer Pricing

Distance Learning Course on Business Restructuring and Valuation, Transfer Pricing Legislation and Guidelines, and other hot Transfer Pricing topics

How to deal with international Transfer Pricing risk?
Transfer Pricing has drawn the attention of tax authorities worldwide. New rules, documentation requirements and different interpretation given to the OECD Transfer Pricing 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 Transfer Pricing course will focus on major Transfer Pricing issues and concerns that all professionals involved in the complex area of Transfer Pricing will face such as: Business Restructuring and Valuation, Transfer Pricing Legislation and Guidelines, Documentation Requirements per region and per country, Transfer Pricing Project and Risk management, Transfer Pricing (pre-) Controversy Management, Design and Development of a Transfer Pricing Policy, types of Intercompany Transactions, Intellectual Property and Customs.

Target group
This new toplevel distance learning Transfer Pricing course has been designed to provide in depth training for financial, tax and Transfer Pricing professionals who are interested in expanding their knowledge of the theory and practice of Transfer Pricing.

The course is relevant for Transfer Pricing managers, (inter)national tax managers and firms, finance directors, treasurers, senior executives with an interest in the latest developments in Transfer Pricing and lawyers and accountants who serve their clients with Transfer Pricing issues and have to guide them in the ever-changing Transfer Pricing 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.

Course materials
The course consists of 11 lessons, each of which will require about 4 hours of self-study. Next to the lessons, you will also receive 'The Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations' by OECD. All course participants receive a Certificate of Participation.

Continuing Professional Education (CPE)
It should be noted that this Transfer Pricing 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.

Feedback of our participants
'The course provides in-depth knowledge on Transfer Pricing related issues. It is a great chance to build up a strong base in TP. I appreciate the effort by TPA professionals and IMF in providing such a fine course.’
Mrs. Shikha Mehta, Transfer Pricing Specialist, Novozymes South Asia Pvt. Ltd.

'The material was good, with useful references to OECD guidelines etc. It is a very thorough course, the 2-week interval gives enough time to study the material.'
Mr. Fuglset, Business Controller, Kverneland Group

'Very interesting course.'
Tax Manager

'In my opinion everything was correct, all lessons were great. The easiest way of learning, especially for business people.'
Ms. Kramar, Director, Krako-Revizija d.o.o.

Transfer Pricing 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.

For courses in Dutch, please have a look at www.imf-online.com.

In-house Transfer Pricing training:

saves time and money;
enables you to train in the comfort of your own working environment;
can be arranged for groups of 6 people or more;
will take place at a time chosen by and convenient for you; and
sensitive issues can be openly discussed because there are no ‘outsiders’.

Are you interested? Please call us at +31 (0)40 - 246 02 20 or send an e-mail to info@imf-online.com to discuss the possibilities.

LESSON I
Transfer Pricing: Introduction

The context of the Transfer Pricing Process
Basic Principles and Terminology, Methodologies

LESSON II
Documentation Requirements in the regulatory context of Transfer Pricing

The OECD Transfer Pricing Guidelines
Factors determining Comparability
Introduction to Transfer Pricing Methods

LESSON III
Transfer Pricing Legislation and Guidelines

US - the country of origin
OECD - setting a global standard
Europe
Australia
Austria
Latin America
Trends in national, regional and global Documentation Standards

LESSON IV
Design and Implementation of a Transfer Pricing Policy

The Transfer Pricing Process
Designing examples for Goods, Services and Intangibles

LESSON V
Transfer Pricing Documentation: practical aspects

Transfer Pricing Documentation – three concepts
Use of the Master File in practice
Use of country-specific Files in practice
Best practices of Transfer Pricing Documentation

LESSON VI
Transfer Pricing (pre-) Controversy Management

Connectivity between 4 boxes
Audit procedure
Advance Pricing Agreements (APA)
Mutual Agreement Procedure (MAP)
EU Arbitration Convention
Penalties and Interest
Pre-Controversy Management Tools
Case examples

LESSON VII
Transfer Pricing Project and Risk Management

Transfer Pricing Project Management
Transfer Pricing Documentation and Risk Assessment

LESSON VIII
Types of inter-company Transactions

List and examples of the most common inter-company Transactions
List and examples of more complex inter-company Transactions
Toolbox for analysis

LESSON IX
Transfer Pricing of Intangibles

The context of Transfer Pricing of Intangibles
Labelling of Intangibles
Identification of Intangibles
Ownership of Intangibles
Valuation of Intangibles
Examples

LESSON X
Business Restructuring and Valuation

Definition of Business Restructuring
Country-specific considerations
Analysis of the situation before versus after Business Restructuring
Valuation aspects of a Business Restructuring
OECD Guidelines Chapter IX
TR 2010/D2
Case Study

LESSON XI
Transfer Pricing and Customs

Differences and similarities between the 2 sets of rules
The international debate on harmonization of Transfer Pricing and Customs Valuation
Price and Profit Adjustments

Request brochure

Highly acclaimed instructors from Transfer Pricing Associates

Transfer Pricing Associates, part of the TPA Global group, is the leading independent provider of global Transfer Pricing services. TPA has offices and coverage in over 30 countries around the world and has an extensive practical knowledge and experience in a broad range of Transfer Pricing issues. TPA provides high quality Transfer Pricing advice and assistance to multinationals of all sizes, wherever they are located. For more details of the innovative services of TPA, please vist their website www.tpa-global.com.

The editors of the Transfer Pricing course are:

Steef Huibregtse
Steef 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.

Rudolf Sinx
Rudolf Sinx is global partner of Transfer Pricing Associates Global Group and has over 20 years of experience in many industries with extensive exposure to Transfer Pricing. Before joining TPA, Rudolf was partner and head of the Transfer Pricing team at Mazars, and key member of the Transfer Pricing team at Loyens & Loeff. He is author of the International Transfer Pricing Journal.

The authors are:

Enrico de Angelis, Partner TPA Customs, previously employed as Senior Associate with KPMG Meijburg & Co
Steven Carey, Global Partner TPA, previously employed asSenior Manager with PwC
Douglas Fone, Partner TPA Australia, previously employed as Director with PwC and Senior Manager with KPMG
Arnas Laurynas, Transfer Pricing Specialist / Senior Associate TPA, previously employed as Senior Tax Consultant bij PwC
Rezan Okten, Senior Associate TPA, previously employed as Transfer Pricing Consultant with Deloitte
Mark Peeters, Senior Associate TPA, previously employed as Senior Manager Transfer Pricing with Ernst & Young and Manager Global Transfer Pricing Services with KPMG Meijburg & Co
Carsten Schmid, Partner TPA Germany, previously employed as Director International Tax Law with the Bundesverband der Deutschen Industrie e.V.
Sowmya Varadharajan, Senior Manager TPA Asia, previously employed as Transfer Pricing Specialist with PwC
Louan Verdoner, Off Counsel at TPA, previously employed as Chief Fiscal Department with Solvay

The distance learning course 'Transfer Pricing' starts on 19 January 2012 and 16 February 2012 . On the date of your choice you will receive your first lesson. Subsequently you will receive a new lesson every week. Since it concerns a distance learning course, you also have the possibility to start at another date. Please select your preference in the form below. At the end of the distance learning course 'Transfer Pricing' you will receive a certificate of participation.

Balanced Scorecard (BSC)

The fee for this distance learning course is € 2.480,- (for VAT registered companies in the EU countries 0% VAT).

For participants from all other countries the course fee  is $ 3.500,- (all-in).* Please ask for our attractive group discounts.

Purely indicative, the price is ± 160.000 Indian Rupees.

*USD price is an approximate value. The actual USD price is based on the invoice date's exchange rate.

Step 3/4: Company details

Invoice data

Company name

Department

Purchase number

VAT number

Address

ZIP Code

City

Country

I would like to receive the course at a different address

Step 4/4: Check and Confirm

You are signing up for:

Transfer Pricing - € 2.480,- $ 3.500,-

Total: excl. VAT (if applicable)

Start date:

Interval:

Participant details

Gender:

Title(s):

Initial(s):

Surname:

Job title:

Phone number:

Fax number:

E-mail address:

Company details

Company name:

Department:

Purchase number:

VAT number:

Address:

ZIP Code:

City:

Country:

Shipping address

I would like to receive the course at the following address.

Company name:

For attention of:

Department:

Address:

ZIP Code:

City:

Country:

Remarks

Where did you hear about us?

Google

Website

E-mail

Colleague