1 day (6 CPD Hours)
Introduction
This course will explain the intricacies of the UK transfer pricing legislation and its relationship to transfer pricing rules in other countries and the impact of EU law and practice. It will analyse practical rules in setting arm's length terms for intra-group transactions and their documentation, and guide you through the procedures for transfer pricing enquiries and resolution of disputes in light of the HMRC litigation and settlement strategy and modern business restructuring.
The course in detail
- The statutory framework in Taxes Act 1988 Schedule 28AA. This includes the nature of the arm’s length rule, its procedural and practical application and relationship with other parts of the tax code.
- Interaction between domestic law and tax treaty provisions with particular reference to Article 9 and the “special relationship” rules of the OECD Model.
- Penalties.
- Specific transfer pricing documentation requirements.
- HMRC Guidance.
- OECD Transfer Pricing Guidelines and the establishment of arm's length pricing.
- EU transfer pricing initiatives.
- Special measures for small and medium enterprises.
- Advance Pricing Agreements and other mechanisms to improve certainty.
- HMRC approach to risk and conducting enquiries.
- Resolving domestic and international transfer pricing disputes and litigation
What are the benefits of attending?
Transfer pricing is the most lucrative area of investigative work for HMRC. The legislation in this area is now twenty times the amount that it was prior to the incorporation of transfer pricing into self assessment with extensive interpretation material from the HMRC and OECD. Other countries have also introduced laws in this area and allocated resources to increase their share of global taxes. Tax barrister Jonathan Schwarz is recognized in this important area and a contributor to the recent book: Transfer Pricing and Business Restructurings.
Who should attend?
- Accountants, lawyers and other tax advisers dealing with corporate groups and cross-border transactions.
- Finance and tax directors, and tax managers.
List of events
|
Date |
Time |
Location |
Code |
Options |
| 05 Nov 2010 |
9:30 -17:15 |
London |
10CO078 |
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details |
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