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Salmah Muhd

  • 2 Days of training
  • E-Certificate of Completion
  • E-Training manual
  • HRDF Approved & Claimable

Course Objectives

  • Explain in detail the transfer pricing framework and core concepts
  • Understand the five methodologies for determining arm’s length pricing from a managerial and a tax administration perspective
  • Discuss the merits of arm’s length pricing methodologies and latest initiatives in the 2017 OECD Transfer Pricing Guidelines (post Base Erosion Profit Shifting guidance)
  • Improved understanding of the business value chain and its connection to functional analysis in connection to global strategies
  • Appreciate the relationship between transfer pricing and other areas of tax law (e.g., GAAR, customs duty and GST
  • Understand key domestic and international case law developments in the context of transfer pricing
  • Prepare transfer pricing documentation, compliant with latest requirements of revenue authorities
  • Use of appropriate data in comparability studies that support pricing outcomes
  • Understand the importance of analysing statutory and management accounts to detect transfer pricing risks

Target Audience

Chief Financial Officers, Financial Controllers, Finance Managers, Accountants, Tax Consultants, Company Secretaries, Tax Practitioners/Advisors.

Methodology

Interactive Lectures, Discussions and Case Studies

Course Modules

  • Module 1 – Introduction to transfer pricing and international business strategies

  • Module 2 – Transfer pricing methods, Comparability analysis with economic and industry considerations

  • Module 3 – Transfer pricing documentation requirements and transparency initiatives

  • Module 4 – Transfer pricing risk management and tax audit techniques to Understand Financial Accounts

  • Module 5 – Transfer pricing intangibles, including Hard to Value Intangibles (HTVI) and cost contribution agreements (CCA)

  • Module 6 – Transfer Pricing Issues in Developing Countries

  • Module 7 – Intra-group services and offshore service hubs, Business restructurings (BRs) and Intra-group finance transactions

  • Module 8: Mechanisms for resolution of transfer pricing disputes, Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APA).

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