Advanced Transfer Pricing – Loans and other Financial Transactions

Speaker:  Gareth Green  |  CPD Hours: 6.0

Price £595 plus VAT

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OBJECTIVES

Intragroup loans and other financial transactions are ubiquitous within multinational groups and transfer pricing legislation therefore requires the pricing of these transactions (such as the loan interest rate) to meet the arm’s length test. This training course aims to provide a practical guide to how to apply transfer pricing rules to such transactions.

Despite the fact that almost all multinationals have intragroup financial transactions, there has historically been remarkably little guidance available on this topic. Textbooks have tended to focus on supplies of goods and services and intangibles, and the assumption seems to be that it is obvious how to adapt the principles to financial transactions. In fact, the issues to be taken into account are quite different.

The OECD is currently working to redress the balance, with its draft guidance issued in July 2018, though it is unclear whether, and when, this will be finalised. The course will explain the draft guidance and will suggest solutions for the areas where the draft is unclear. If the guidance is finalised (or a new draft is issued) the course will be updated accordingly.

The Advanced Transfer Pricing course is not specific to any particular country; it is based on international norms. Nor is it specific to any industry; it covers transactions that arise in almost all industries.

CONTENT

In order to be as practical and interactive as possible, the course will be taught by way of discussion of a series of case studies covering topics such as the following:

Interest rates

  • Arm’s length rates
  • Safe harbours
  • Country risk
  • Intercompany balances

Thin capitalisation

Interest-free loans

Group treasury companies

Cash pooling

Guarantees

The content incorporates the impact of the new principles introduced by the OECD as a result of its BEPS project.

WHO SHOULD ATTEND

Tax, accounting, or legal professionals working in-house or in an advisory firm, who need to understand how, in practice, to approach transfer pricing for financial transactions.

Participants will find it helpful to have an understanding of:

  • general transfer pricing principles (such as are covered in the Fundamentals of Transfer Pricing course)
  • accounting, including the contents of profit and loss accounts and balance sheets
  • economic concepts affecting businesses, such as supply and demand and opportunity costs.

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