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STARTS SEPTEMBER 18TH, OCTOBER 16TH & NOVEMBER 20TH
Do you want to:
Make an assessment of your TP risks?
Learn how to deal with the different levels of documentation required by the different tax authorities?
Avoid duplication of documents (danger of inconsistencies!) in various countries?
Organize, maintain, defend and modify your TP system yourself?
Benchmark your TP system against best practices?
Then this is the course for you.
This new advanced toplevel TP distance learning course has been designed to provide in depth training for financial, tax and TP professionals who are interested in expanding their knowledge of the theory and practice of TP.
Transfer Pricing has drawn the attention of tax authorities worldwide. New rules, documentation requirements and different interpretations given to the OECD TP Guidelines by both tax authorities and multinationals have created ground for many disputes.
This course will give you a sound understanding of the many complex issues like intangibles involved in TP. Also the concern you should have about TP affecting your supply chain is an issue in this course. A TP documentation package allows you to prove that you have done your ‘homework’ and are able to communicate this with the tax authorities. Also tools and tips to more effectively and cost efficiently (re)design and align your TP system when, for example, a business model is changed or a new business model is adopted, is one of the important parts of this course. How to resolve many TP documentation issues is also a hot topic. In the last lesson you will find a summary of the TP regimes of several countries.
Why a distance learning course?
Distance learning courses have several advantages. First, you can follow a course at your own pace, whenever and wherever you wish. Distance learning courses require no time and expenses for travelling, no accommodation expenses and more important, you do not have to leave the office for several days. According to various estimates, a distance learning course generates cost savings of about 40 - 60% of normal course expenses! In addition, the course provides you with a practical, high-quality reference book after you have completed the course. The high quality of IMF courses is guaranteed by the authors.
Highly acclaimed instructors from Deloitte's Transfer Pricing Group
Your TP authors, who are all highly acclaimed instructors with international backgrounds and all working with Deloitte TP Group, use their significant TP experience and knowledge to assist you in managing and minimizing global tax rates.
Chief editor of this course is Thijs Heijenrath, International Tax partner and head of Deloitte TP Group.
The authors have been involved in a variety of projects, ranging from TP documentation, valuation and negotiation to (re)structuring. They all serve as TP specialists in both defence and dispute resolution situations and have negotiated a significant number of APA’s with Dutch and foreign tax authorities. The Deloitte approach has been recognized by many tax authorities as the right way of doing your ‘TP homework’.
The instructors are fully aware of current and future developments and will leave you with an excellent knowledge on many important TP issues.
Course description
I Introduction
The OECD TP Guidelines
Factors determining comparability
Introduction to TP methods
II Transfer Pricing Methods
Arm’s Length Principle
OECD TP Methods
Traditional Transaction Methods
Transactional Profit Methods
Practical Application of a Financial Analysis (INMM)
Reference Materials
III Intra Group Services
OECD Guidelines on intra-group services
General observations for Headquarters Services
IV IP Intangibles
Arm’s length pricing
Recent developments
Case studies
V Cost Contributions Agreements
OECD TP Guidelines on Cost Contribution Agreements
Buy-In and Buy-Out Payments
Country specific previews
Reference Materials
VI Transfer Pricing Disputes
Advance Pricing Agreements (APA)
Mutual Agreement Procedures
EU Arbitration Convention
Reference Materials
VII Documentation Requirements
TP documentation requirements
EU-wide TP Documentation
VIII Supply Chain Conversion
Supply Chain Strategies
Restructuring - case study
IX Country Surveys
Brazil Germany India Poland Switzerland
Start course
This topical course consists of nine lessons, each of which will require approximately four hours of self study.
You can start on May 15th, June 19th and July 17th 2008. Should you wish to start on an alternative date, please let us know.
Personal assistance
Should you have any questions about the lessons, please feel free to contact the authors or International Management Forum.
Target group
This course on Transfer Pricing is particularly relevant for Transfer Pricing managers, international tax managers and directors, controllers, treasurers, chief financial officers, senior executives with an interest in the latest developments in Transfer Pricing and lawyers and accountants who service their clients with TP issues.
The fee for this course on TP by Deloitte amounts to $ 3850/€ 2.480,- (excl. VAT).
However, we can offer you the following group discount if two or more of your colleagues will participate in this course;
• 2-3 individuals: $3465/€ 2.232,- (10 % discount)
• 4-5 individuals: $3272/€ 2.108,- (15 % discount)
• 5+ individuals: $3080/€ 1.984,- (20% discount)
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