Course Info
Code PF1-131
Duration 5 Days
Format Online
Course Summary
Taxation is an important aspect every organisation should be aware and competent in. Regulations are constantly being created and updated to maintain an efficient practice and ensure all parties involved are protected.
When it comes to taxation laws, it is crucial to understand them at an international level, as general business practices often involve international trade. An organisation will always attempt to find the ideal trade price to maximise their profits, and taxation laws often greatly increase the outgoing costs when making these sales.
There are several frameworks in place to create a fair taxation environment. BEPS Action plan was established as strict yet extensive guidelines on taxation, and alongside it implemented tax treaties to add an extra protection layer for both buyer and seller. These tax treaties inherently come with anti-abuse rules to prevent exploitation.
However, there are still various methods of transfer pricing to be utilised for an organisation to guarantee a profitable income. For an effective outcome, there are a range of software that can calculate the ideal solution. The ideal method will vary depending on service or product being sold, the buyer and location of the trade.
- To understand the vitality of taxation law.
- To review tax laws on a local, regional and international level.
- To assess the relationship between different tax laws and their implications.
- To identify effective legal design approaches.
- To evaluate key policy issues and ideal approaches to overcome them.
- To examine domestic tax legislation in comparison to international practices.
- To describe the benefits of the BEPS action plan.
- To analyse how transfer pricing practice has evolved over time.
- To identify the role of tax treaties and the benefits and limitations.
This course is designed for anyone with the responsibility of managing finance and taxes within an organisation. It would be most beneficial for:
- Accountants
- Finance Managers
- Finance Directors
- Investment Analysts
- Risk Managers and Analysts
- Tax Advisors
- Business Owners
This course uses a variety of adult learning styles to aid full understanding and comprehension. Participants will review genuine real-world case studies of established organisation’s taxes to highlight relevant tax treaties and transfer pricing methods.
They will be provided with the essential tools required to successfully carry out the given learning exercises. Participants will partake in various presentations, group discussions, role-playing activities and practical activities to ensure they have a full and comprehensive understanding of the taught knowledge. In a group activity, participants will create their own transfer pricing documentation and establish a transfer pricing method for their given case study. This will allow them to put their knowledge into action to ensure extensive understanding.
Course Content & Outline
- Understanding the international tax environment.
- The history of the international tax regime.
- Factors that influence the current culture of taxation.
- The concepts and purpose of the arm’s length principle.
- The benefits of utilising the arm’s length principle.
- Defining BEPS and the OECD.
- Reviewing the 15 actions of BEPS and the purpose they serve.
- How practical tax treaty application was changed post-BEPS implementation.
- OECD BEPS Action 15 on the Multilateral Instrument (MLI).
- Determining the beneficial ownership status and the two types of ownership.
- Typical corporate tax structuring.
- The importance of treaty anti-abuse rules.
- Maintaining intra-firm relations.
- Understanding the purpose of transfer pricing.
- The various services and goods that transfer pricing applies to.
- Describing relative MNE groups.
- The vitality of transfer pricing to states and to MNE groups.
- Applying the arm’s length principle to transfer pricing.
- Defining key terms.
- Reviewing the various methods of transfer pricing –
- Comparable Uncontrolled Price (CUP)
- Resale Price method (RPM)
- Cost-plus method
- Transactional Net Margin method (TNMM)
- Profit Split method (PSM).
- Analysing the advantages and disadvantages for each method.
- Evaluating what methods would be most effective for a service or product.
- Utilising programs and software to reach the most ideal transfer pricing method.
- The purpose of transfer pricing documentation.
- The OECD's guidance on transfer pricing.
- Potential compliance issues and ways of resolving them.
- Utilising tax treaties to resolve disputes (BEPS Action 14).
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