The OECD, EU and UN have been and are still implementing guidance related to base erosion and profit shifting (BEPS), and many of these developments affect transfer pricing. Many countries in the Asia-Pacific region (e.g. India, Indonesia, Vietnam, Malaysia and Thailand) have partially or fully implemented into their legislation the three-tiered standardized OECD approach to transfer pricing (TP) documentation or are planning to do so. In addition, tax authorities across the Asia-Pacific region are or have been reviewing their current rules and audit frameworks to consider and implement concepts around “substance” and “value creation”, in line with the guidance contained in Actions 8-10 of the OECD BEPS project. With the increased focus on BEPS, many companies today face transfer pricing disputes in more countries than one. The aforementioned developments require a different approach from both tax authorities and multinational enterprises towards transfer pricing. Each session of this course will therefore address the international frameworks that are in place, the legislation/guidance that is in place, and approach that is taken by tax authorities in several jurisdictions in the Asia-Pacific region.
This course consists of theoretical sessions which are complemented by case studies and examples. The objective of this course is to understand the key aspects of transfer pricing. Upon completion of the course, participants will be able to:
- Assess potential transfer pricing risks as well as potential transfer pricing opportunities;
- Explain the most recent transfer pricing developments;
- Find comparables, understand the different comparability factors and determine which comparability adjustments can be made;
- Determine an arm’s length price for various intra-group transactions;
- Name the different elements of a CbC report, Master File and Local File;
- Apply in practice the examples analysed during the training.