Transfer Pricing Fundamentals

Fundamental Transfer Pricing Issues

• Pricing theory and its relevance to current tax issues
• Risk Assessment on Transfer Pricing
• Valid Transfer Pricing data and methodologies:
  • Consideration of the different OECD-approved transfer pricing methods
  • Cost plus
  • Transactional net margin method
  • Profit split
  • Residual profit split
  • Resell minus.
  • The use of comparable uncontrolled pricing (CUP)
• Building up your defences against HMRC action
• How to conclude a settlement
• Mutual agreement procedures
• Relevant case law
• Interaction with the Diverted Profits Tax

For in-house tax teams, our transfer pricing courses have been designed to bring together the different departments that have an impact on Transfer Pricing, this includes:

• Finance
• Legal
• HR
• Company secretarial

Throughout the day, there will be a series of case studies which look at the impact of Transfer Pricing on different locations in which the business is situated and the varying departments.

Bringing Transfer Pricing Up-to-Date

Although the concept of Transfer Pricing is not new it is the focus of increased attention by Revenue authorities and can result in the diversion of substantial resources and costs in terms of a final tax settlement.

The activities of some well-known multinationals have provoked severe responses in terms of the media and public opinion, leading to not only tax issues but also reputational risk. In turn, Parliament has put more pressure on Revenue authorities to deal more robustly with “aggressive tax avoiders”. Inevitably, more companies will find themselves under the microscope.

In 2019 HMRC acquired new powers in respect of countering “profit fragmentation”. This marks a radical departure from previous legislation on transfer pricing as there is no exemption for small and medium-sized companies.

The course is delivered by the Director of a consultancy company specialising in taxation, share scheme advice, reward and lecturing. He has developed a specialised share scheme service for small companies and advises FTSE companies on communication. The lecturing side of his work covers most aspects of Direct Taxation but his particular interests include employment taxation and transfer pricing, which poses unusual conceptual challenges.

With almost 9 years dedicated to Henderson before the above, he led the Share Schemes team for part of this time.

This specialist took the level 7 CIPD Masters qualification whilst at Henderson. Before Henderson, he was with Australian Mutual Provident (AMP) and helped set up one of the first Share Incentive Plans (SIP) for large companies in 2001. It was so unusual at the time that the Revenue phoned the trainer to find out how they could encourage more large companies to adopt SIP.

He began his career in taxation and for the following 16 years, he worked in three of the “Big Four” accountancy firms before landing a Senior Manager role with Deloitte & Touche having worked on issues such as profit-related pay, share schemes, expatriate tax, tax investigations, reward management, US taxation, transfer pricing and corporate tax.

Away from work, our trainer likes cricket, history, skiing, tennis and gardening. He gives lectures on history which helps keep his presentation skills fresh.

• Redcliffe’s transfer pricing courses take participants through the OECD Principles governing transfer pricing and look at the framework for transfer pricing which is underpinned by the OECD model treaty
• The changes which have come about as a result of the BEPS process
• The practical application of transfer pricing from an individual state basis, notably in the UK and US

This transfer pricing course will appeal to both tax specialists in transfer pricing as well as those who have a discipline outside the area. It sets out the fundamental objectives that Revenue Authorities have in terms of pricing and it looks at how Multinational Companies can reduce their risk. We look from the perspectives of both the taxpayer and Revenue Authorities in a balanced way which provides a greater understanding of the objectives that they are trying to achieve.

We will equip participants with a knowledge of how transfer pricing works in terms of both legislation and practice. We estimate this transfer pricing online course should run for about six hours, as well as six hours for any in-house face-to-face presentations.

Participants should be well-versed both in the legislation and practice regarding transfer pricing.