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Transfer Pricing & Intangibles

High-level course on Taxation and Valuation of Intellectual Property (IP) and other Intangible Assets

Transfer Pricing & Intangibles – mode of study

Option 1: Distance learning course (incl. digital learning)
Option 2: In-company course customized for your organisation. 

Transfer Pricing & Intangibles – one of the most important areas of Transfer Pricing today!

With the shift towards a more knowledge-based and service-oriented economy, intangible assets such as trademarks, brands, patents, know-how and technology, account for an increasing part of the business value. The accurate and complete taxation and valuation of Intellectual Property (IP) and other intangible assets is therefore essential.

Also see: Transfer Pricing; BEPS Expert; Transfer Pricing Professional online; Certified Fraud Examiner (CFE); Business Valuation & Financial Modelling

Transfer Pricing & Intangibles – a continuing battlefield

Intangibles is one of the most important areas of Transfer Pricing at the moment. General consensus among taxpayers and tax authorities alike is that there is currently insufficient international guidance, in particular regarding the definition, identification and valuation of intangibles for Transfer Pricing purposes. The outcomes of OECDs project on intangibles are likely be far reaching and as such this promises to be the most challenging and ambitious project that OECD have undertaken to date.

What will you learn?

In this unique distance learning course your instructors will look at intangibles from the complementary perspectives of Transfer Pricing and valuation. As there is no single definition of Intellectual Property (IP)  and other intangibles in use today by tax authorities or the OECD, the authors provide a framework in order to capture the various characteristics of Intellectual Property. Next, they touch upon the methods that have been provided by the OECD to establish arms length pricing or valuation of intra-group transactions of Intellectual Property (IP), as well as the practical implementation of these methods.

For who?

This unique, toplevel distance learning course on Transfer Pricing & Intangibles is a must for Corporate Tax and Intellectual Property Legal Counsels, Intellectual Property and Licensing Executives, in-house Transfer Pricing Managers, Advisors Transfer Pricing, International Tax Executives, Tax Directors, Accountants, Tax Inspectors, Controllers and CFOs, Tax Attorneys and Solicitors, CPAs and Lawyers, and many other professionals.

Prerequisites

There are no specific requirements for succesfully studying this toplevel Transfer Pricing & Intangibles course. 

Language

The Transfer Pricing & Intangibles course is written at a higher educational level. 

Continuing Professional Education (CPE)

It should be noted that the course Transfer Pricing & Intangibles 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.

Study time

The distance learning course on Transfer Pricing & Intangibles consists of 7 lessons, each of which will require an average 4 hours self-study.

Certificate

You receive a personal certificate. 

Transfer Pricing & Intangibles – feedback

The Transfer Pricing & Intangibles course is assessed by former subscribers with a 9! 

Partners

Would you like your logo/banner to be displayed here or are you interested in becoming a marketingpartner? Join us now and your business will have top exposure on our website, in our brochures and in our finance/tax newsletter. Contact us for more information!

 

In-company

Transfer Pricing – in-company (and customized)

Do you prefer an in-house and customized course on Transfer Pricing & Intangibles? An in-company course on Transfer Pricing & Intangibles, customized for your organisation, has many advantages and:

  • Saves you and your colleagues time, travel and accomodation costs
  • Enables you to train in the comfort of your own working environment
  • Can be arranged at a time convenient for you
  • Sensitive issues can be openly discussed because there are no outsiders
  • Can be arranged for groups with a minimum of 5 people

For more information on this Transfer Pricing & Intangibles course, the in-house possibilities or for any other question, please contact us directly at +31 (0)40 – 246 02 20 or send an e-mail to info@imfacademy.com.

Why a distance learning course?

IMF Academy uses distance learning as an alternative and a complement to traditional in-class trainings in order to make high-level course materials accessible to large audiences worldwide. The greatest advantage is not to be confined by such constraints as geographical location and time. Any client, anywhere in the world, can benefit from IMF Academy's distance learning programs at a time and place convenient to him or her. At the end of every distance learning course, you receive a personal certificate, acknowledging completion of the course.

Advantages

This Transfer Pricing & Intangibles course is also available as digital learning. 

Content

LESSON I
Transfer Pricing and Intangibles – Introduction

Today, intangible property generally represents between 40-80% of value-add of international enterprises (MNEs), making it a key component of a MNEs value chain. Intangible property includes business rights associated with commercial activities, including marketing activities. Intangible property will not always be shown on the balance sheet of a company, and often intangible property attracts a considerable risk, e.g. contract or product liability.

Given that Transfer Pricing issues pertaining to intangibles are a key area of concern to governments and taxpayers, the OECD found that updating Chapter VI and VIII of the OECD Transfer Pricing Guidelines has become an increasingly important issue in the evolution of new business realities and subsequent adaptations to the Transfer Pricing regulations.

  • The evolution of the MNE and the importance of intangibles
  • OECD Definition of Intangible Property
  • How do emerging jurisdictions (i.e. BRICS) deal with intangibles?
  • Transfer Pricing and Intangibles: 4 functional variables
  • Locating Intellectual Property (IP) in tax advantaged jurisdictions
  • Transfer Pricing Risks (I): Court Cases on Intangibles
  • Transfer Pricing Risks (II): Corporate Reputation at Risk Through SEC Disclosure of Intercompany Transactions
  • Questions & Answers
  • Literature

LESSON II
Intangibles – Transfer Pricing labels, identification and ownership

Lesson II evaluates the labels that are applied to intangibles in the context of Transfer Pricing by utilizing 4 functional variables. The definitions of intangibles are evaluated from a legal, tax and accounting perspective. The lesson examines methods for applying labels to intangibles and how to properly identify the rightful owners and which entity is entitled to the returns related to an intangible.

  • Definition of intangibles
  • Labelling of intangibles
  • Questions & Answers

LESSON III
Valuation of Intangibles

Lesson III provides a clear picture of the various aspects of assessing the value of an intangible for Transfer Pricing purposes. This is accomplished through providing relevant background information, introducing components of valuation methods and applying the ideas to real world examples of highly valued companies that utilize intangibles in their business models. After introducing these concepts, practical methods of assessing value are examined.

  • When and why Intangible Assets are valuable
  • Companies with highly valued intangibles
  • Why and when are intangibles valued?
  • Price, Value and Cost   
  • Generally Accepted Valuation Approaches
  • Determining the Discount Rate and Capitalization Rate
  • Business Restructuring and Valuation, Chapter IX, OECD
  • Questions & Answers

LESSON IV
Business Models – Intellectual Property (IP) configurations

Lesson IV describes how and where intangibles are located in the value chain of multinational enterprises. This is accomplished through evaluating business models from a general business/commercial perspective as well as from a Transfer Pricing perspective. Case studies and questions to evaluate different practical examples are included in this lesson.

  • Overview of business models from a commercial perspective
  • Transfer Pricing and general corporate tax considerations of each model
  • Model implementation – high level guidance on implementing each of the above mentioned models, including a legal framework for managing Intellectual Property
  • Case Study
  • Questions with model answers
  • Multiple choice questions
  • Answers to open and multiple choice questions
  • Literature

LESSON V
Intellectual Property (IP) law and Transfer Pricing

Lesson V examines the legal system surrounding Intellectual Property rights. The lesson provides a brief history of Intellectual Property rights in the legal context, discusses the future of Intellectual Property rights, and looks at the different types of legally recognized Intellectual Property rights. The lesson further explores on the legal aspects of Intellectual Property exploitation, Intellectual Property management and Intellectual Property transfer. How to protect intangibles through Intellectual Property law, corporate law, contract law and labour law is also examined.

  • Brief History of Intellectual Property
  • Future of Intellectual Property
  • Appearance of Intellectual Property
  • IP exploitation
  • IP management
  • IP transfer
  • Questions & Answers

LESSON VI
Intangibles – Accounting definitions

Lesson VI provides a high level overview of the accounting standards relating to intangible assets. The lesson focuses on the recognition and measurement of intangibles according to accounting principles. The lesson examines the differences in valuation of intellectual property according to IFRS, US GAAP and Canadian Gaap.

  • Introduction Intangibles
  • Recognition of Intangibles
  • Goodwill
  • Subsequent measurement
  • Questions & Answers
  • Literature

LESSON VII
Transfer Pricing & Intangibles – corporate income tax aspects

Lesson VII outlines the corporate income tax aspects related to intangibles and Transfer Pricing. The lesson touches on many tax aspects, including amortization, tax credits, capital gains tax, value-added tax, and more. Several examples from different countries are provided to highlight how intangible property is taxed around the world.

  • Initial Intangible Asset Value
  • Amortization/Decrease in the Value of Intangible Assets
  • R&D Tax Credit
  • Innovation Box/other Incentives
  • Replacement Reserve
  • Withholding Tax on Royalty Payments
  • Capital Gains Tax
  • Business Restructuring and Related Taxes
  • VAT
  • Purchase Price Allocation
  • Beneficial/Economic/Legal Ownership
  • Conclusion
  • Questions & Answers

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Trainer(s)

Transfer Pricing & Intangibles – highly acclaimed instructors from TPA Global
Your highly acclaimed instructors are all member of TPA Global, a solution house in 60+ countries on business, tax and technology. The chief editor of this course is:
  
Steef Huibregtse
Steef Huibregtse is the founder and CEO of TPA Global. Steef has more than 30 years experience in the area of Transfer Pricing strategy, value chain analysis, digital transformation and data factories, risk management, design, documentation, controversy management and implementation. Steef recently launched a global tax controversy platform with the 'best in class litigators and mediators'. Steef himself frequently acts as expert witness on global/regional transfer pricing/BEPS disputes.

Start date(s)

The distance learning course on ' Transfer Pricing & Intangibles' starts on 19 September 2019 and 17 October 2019 Since this is a distance learning course, it is also possible to start on any other date you desire. On the registration form you can indicate your preferred start date, choose the interval for receiving the paper lessons and indicate whether you wish to make use of our free digital learning service in order to study the course online. You will receive the full course in one shipment. We advise you to study 1 lesson per week, each of which will require about 4 hours of self-study.

N.B. when you live in The Netherlands, you can choose to receive the first lesson on the date of your choice, whereafter we will periodically send you one lesson (depending on the interval you chose). However, if you choose to study the Transfer Pricing course online, you will receive the full course in one shipment also.

Fee / Registration

The fee for the distance learning course on Transfer Pricing & Intangibles is € 2,180 (VAT excl).

 



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Payment
Payment of the Transfer Pricing & Intangibles distance learning course must be received before the start of the course

Transfer Pricing & Intangibles

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