Fundamentals of transfer pricing - new course for 2010

How you will benefit

• Learn the basics of transfer pricing theory and legislation
• Be able to identify, analyse and prioritise transfer pricing risks;
• Understand the key steps required to develop a transfer pricing policy and support it using documentation and other methods;
• Learn how to conduct a functional analysis to identify functions performed, risks assumed and assets employed in respect of intra-group transactions, and characterise the entities involved;
• Learn how to select and apply the most appropriate transfer pricing method based on the nature of the intra-group transactions, information available and interpretation of transfer pricing theory;
• Understand the key issues to consider in conducting economic analysis to support intra-group transactions; and
• Be better prepared to defend transfer pricing policies and positions.
• Introduction to advance agreements and dispute resolution

Programme in detail

Day 1

• Overview of UK and other countries' transfer pricing legislation, OECD Transfer Pricing Guidelines and relevant caselaw
• Interaction with tax treaties and permanent establishment concepts
• Transfer Pricing project planning and strategy
• Fact gathering and functional analysis
• Entity characterisation
• Identifying material risks
• Selection of the most appropriate method

Day 2

• Economic analysis: Comparability factors; Benchmarking studies; Comparable company searches
• Key intra-group transactions including: Products; Services; Cost Contribution Arrangements; Intellectual Property; Financing transactions; Documentation

Tutors: Ken Almand and David Sayers, Mazars Transfer Pricing Team

Book online or alternatively, book by phone on +44 (0)20 7847 5804

EATI Members: £998.75

If you register 30 days before event: £948.81

If you register 60 days before event: £898.88

Non Members: £1,222.00

If you register 30 days before event: £1,160.90

If you register 60 days before event: £1,099.80

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