Global transfer pricing—the price at which an enterprise transfers goods, properties and services to associated enterprises—directly impacts a company’s profitability and tax liability. For this reason, global transfer pricing is under increasing scrutiny as more governments seek to increase their tax revenues.
Taught by transfer pricing expert and finance leader David Galmaski, this course explains the nature and implications of global transfer pricing policy, provides an overview of the OECD and its governing role with global tax authorities, and presents real-world examples of “getting it right,” from a business, taxation, and fiduciary perspective. You also hear the instructor’s first-hand experience with MNEs and the gaps identified within existing policies.
Additional content includes:
- Life cycle of a global transfer pricing policy
- Process steps, including functional analysis, business characterization, tax policy and compatibility, comparables analysis, method selection, contemporaneous documentation, and ongoing update and maintenance
- The current environment with respect to revenue audits and transfer pricing audits
- The potential legal and tax exposures resulting from a faulty transfer pricing policy as well as the risks of potential double taxation.
Learning Objectives
- Define the role of the OECD and it’s authority in governing transfer pricing policy globally.
- Assess participant’s current transfer pricing policy against the 5 allowable OECD alternative methodologies.
- Evaluate the risk of double taxation and how to calculate the financial impact.
- Articulate the 7 steps of the transfer pricing policy development cycle.
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Prerequisites
Prerequisite: Experience with corporate income tax and a basic knowledge of international tax and exchange between legal entities within a Multi- National Enterprise
Advanced Preparation: None