Principles of Transfer Pricing

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15 April 2020, Wednesday - 17 April 2020, Friday

09.00AM - 05.00PM
Kuala Lumpur - Malaysia

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Accredited tax professionals enjoy 30% early bird discount (register ≥60 days before course commencement) or 20% discount (before course commencement).
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Programme Synopsis

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.

Programme Outline

  • Introduction to Transfer Pricing
  • Comparability Analysis
  • Transfer Pricing Methods
  • Transfer Pricing and Intangibles
  • Global Supply Chain Considerations and Business Restructuring
  • Intra-Group Services
  • Intra-Group Finance Transactions
  • Documentation
  • Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes

About the Presenter(s)/ Trainer(s)

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Ms Anuschka Bakker
Manager, Transfer Pricing and Specialist Knowledge Group

Anuschka Bakker is the Manager of the Transfer Pricing and Specialist Knowledge Group of IBFD in Amsterdam. In addition, she acts as the Cluster Manager for the transfer pricing courses offered by IBFD International Tax Training. Prior to joining IBFD, she worked for Ernst & Young and PricewaterhouseCoopers. She has many years of experience in international taxation issues, of which the last 12 have been dedicated to transfer pricing. Ms Bakker also lectures and publishes regularly on a wide variety of transfer pricing-related topics. Further, Ms Bakker speaks at transfer pricing conferences around the world.

She holds a master's degree in Tax Law from the University of Groningen, the Netherlands and she holds an MBA from Nyenrode Business University, the Netherlands. Ms Bakker has published over 30 articles and chapters on transfer pricing, tax risk management and tax and environment.

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Mr Subhabrata Dasgupta
Deloitte Malaysia

Subhabrata Dasgupta (Subho) is a partner in the transfer pricing service line of Deloitte Malaysia. He has extensive experience in working with Deloitte network offices in Asia, the EMEA and the Americas on global and regional transfer pricing documentation and planning engagements, involving policy design, implementation, delivery and follow-up/monitoring elements, for US, EU and Asian clientele. He handles a portfolio of both foreign and local multinational and domestic groups.

Mr Dasgupta has more than 12 years’ experience in serving clients from varied industries, such as electronics and electrical, pharmaceuticals, real estate and construction, consumer and industrial products, financial services, telecommunications, oil and gas, primary and secondary metal manufacturing, agribusiness, and aerospace and defence. His assignments have involved global/local documentation, supply chain restructuring and due diligence projects, audit defence, advance pricing agreements, Action 13 transfer pricing documentation and country-by-country reporting, etc. Currently, he leads the TP Technology and FSI offerings from Deloitte in Malaysia.

Mr Dasgupta holds a master’s degree in Commerce from the University of Calcutta (India). He is a frequent moderator and panellist on transfer pricing seminars and workshops organized by business associations and accounting bodies. He has also facilitated trainings for the local tax office. 

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Ms Gita V. Sheth
Assistant Vice President – Tax

Gita V. Sheth is currently employed as Assistant Vice President – Tax with CIMB Bank, a global banking group headquartered in Malaysia and having operations in more than 20 countries with South-East Asia being its main focus market. She manages transfer pricing-related discussions and compliances within the company. 

Ms Sheth has been active in the transfer pricing field for over 11 years, working for various multinational organizations and consulting firms, across Singapore, India and Malaysia.
She has extensive experience in all types of transfer pricing-related work, such as advisory, audit support, compliance, risk assessment and restructuring. She has also been involved in developing audit defence strategies for various transfer pricing matters. 

Ms Sheth has been a regular attendee at various transfer pricing forums and has been a speaker at conferences. She holds a Bachelor of Commerce degree from the University of Calcutta (India) and an MBA from ICFAI University (India).


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