Transfer Pricing: Avoiding Financial Risks and Dealing with Tax Consequences
Overview:This Knowledge Group live webcast: Transfer Pricing: Avoiding Financial Risks and Dealing with Tax Consequences LIVE Webcast aims to put you in the know with respect to understanding key issues surrounding transfer pricing and its impact on your company. Join this two-hour webcast as our key thought leaders and practitioners help you grapple with the ever-evolving landscape of global transfer pricing. They will provide important and timely overview of the recent rules and regulations and case law developments along with training on best practices in avoiding unanticipated financial risks and managing the tax consequences of intercompany transactions.
- Risks associated with transfer pricing
- Risk of audits/adjustments/penalties
- Financial risks
- Operational risks
- Reputational risk
- Risk management framework
- How well transfer pricing risks fit into and can be managed within risk management framework
Recommendations for MNEs
- Transfer Pricing for Intangibles
- Potential Implications of Recent OECD Proposals
- Due Diligence—Reviewing a Taxpayer's Own External Agreements for Intangibles
- Using a Taxpayer's Own Agreements for Intangibles as Potential Comparables
- Tax Planning Issues for Structuring Controlled Transactions and Assigning Returns
Lowering Transfer Pricing Risks Posed by Intercompany Services and Loans
- Impact of US Services Regulations
- Examples of actual audit questions companies are receiving
- What companies are doing to maximize deductibility of services charges
- How to price intercompany loans
- Common pitfalls
- OECD developments impacting intercompany loans
- What companies are doing to defend their loan pricing strategy in an efficient manner
- Pitfalls and Audit Risks
- CBSA: Jockey Canada case
- CRA: Glaxo case
- Best Practices
- Transfer Pricing Studies
- Commercial and Other Documentation
- Case Experiences
- Dispute Resolution
- Responding to the Audit
- Appeals Relief
- Competent Authority Relief
Who Should Attend:
- Transfer Pricing Attorneys & CPAs
- Tax Directors
- Tax Managers
- CFOs & Finance Executives
- Consultants – Transfer Pricing & International Tax
Ms. Mert-Beydilli is a Vice President in NERA's Transfer Pricing Practice. Her areas of expertise are developing and defending effective arm's length transfer pricing strategies for multinational companies. She has extensive experience designing and analyzing intercompany transfer pricing policies and valuation of intangible and intellectual property. Ms. Mert-Beydilli has developed expertise in designing pricing methodologies through the use of value chain analysis, determining appropriate intercompany prices for tangible goods and intercompany services as well as royalties, effective implementation of profit split methods, negotiating and implementing Advance Pricing Agreements with tax authorities, and supporting clients in tax controversy situations. She has advised multinational corporations in a variety of industries, including clients in the automotive, construction, and industrial machinery, information technology services, medical equipment, power generation, money transfer, cosmetics, consumer products, and multilevel marketing industries.
Ms. Mert-Beydilli is a Vice President in NERA's Transfer Pricing Practice. Her areas of expertise are developing and defending effective …
Dr. Korenko is an experienced expert in the application of economics, finance and econometrics to numerous areas including transfer pricing, litigation and complex business matters. In conducting transfer pricing studies, Dr. Korenko has used economic, accounting, financial, and statistical analyses to identify arm's-length prices consistent with U.S. and foreign tax guidelines for intangible property, tangible property, and services. His experience spans a variety of industries, including financial services, pharmaceuticals, computer hardware and software, chemicals, automotive, and others.He has published on topics relating to intellectual property, transfer pricing, and public policy issues and has presented on issues in these areas to a variety of audiences. His work on intellectual property protection in developing countries has been translated into Spanish and distributed in South America, and he has presented at international conferences in Mexico and Brazil.
Dr. Korenko is an experienced expert in the application of economics, finance and econometrics to numerous areas including transfer pricing, …
Michelle has significant experience advising clients on transfer pricing and valuation matters, including transfer pricing documentation preparation, ASC 740 (FIN 48) recognition and measurement analyses, advanced pricing agreements, cost-sharing analyses, buy-in valuations, supply chain restructuring and tangible and intangible transfer pricing policy development. Michelle has assisted numerous clients on revamping their documentation and compliance processes to become more efficient and effective given today's global audit practices. In addition, Michelle has significant experience managing local teams across the globe to harmonize companies' transfer pricing policies and coordinate global documentation in numerous countries.
Michelle led the development of Duff & Phelps' ASC 740 (FIN 48) service line for transfer pricing and pioneered several thought leadership publications. She is an award-winning speaker and has presented at numerous conferences and seminars regarding transfer pricing issues. She served as co-editor of Wolter Kluwer's Guide to International Transfer Pricing: Law, Compliance and Tax Planning Strategies, and co-authored the BNA Tax Management Portfolio on ASC 740-10 (FIN 48) (published 2012). Michelle also oversaw Ceteris' transfer pricing team's US operations and was responsible for quality and training of the company's US transfer pricing practice. Earlier in her career, Michelle was part of Ernst & Young's transfer pricing practice, having spent time in the company's Chicago, San Jose and New York offices.
Michelle obtained her Masters degree in Economics from New York University and a BS in Economics and French from the University of Illinois.
Michelle has significant experience advising clients on transfer pricing and valuation matters, including transfer pricing documentation preparation, ASC 740 (FIN …
Darrel Pearson, co-chair of the firm’s international trade and investment practice, is widely recognized in Canada and abroad for his …
Claire Kennedy provides tax advice on M&A and corporate finance transactions and advises clients on transfer pricing issues in cross-border investments. She also represents clients during tax and transfer pricing audits and appeals and in Competent Authority proceedings. Claire serves on the board of directors of the Bank of Canada, Canada's central bank.
Claire has spoken at tax and business conferences on tax planning and is a frequent speaker on transfer pricing topics, including migration of IP and tax and customs issues in a global supply chain. Claire was selected as National Reporter for Canada on Services Establishments at the International Fiscal Association's 2012 International Congress. Claire is the Liaison with International Organizations for the International Bar Association's Taxes Committee, dealing with OECD BEPS and transfer pricing initiatives, and is on the Council of the Canadian branch of IFA.
Claire Kennedy provides tax advice on M&A and corporate finance transactions and advises clients on transfer pricing issues in cross-border …
Print and review course materials
Method of Presentation:
On-demand Webcast (CLE)
NASBA Field of Study:
NY Category of CLE credit:
Areas of Professional Practice
2.0 CPE (Not eligible for QAS (On-demand) CPE credits)
Unlock All The Knowledge and Credit You Need
Leading Provider of Online Continuing Education
It's As Easy as 1, 2, 3
Get Your 1-Year All Access Pass For Only $199
NERA Economic Consulting
Duff & Phelps
About NERA Economic Consulting
NERA Economic Consulting (www.nera.com) is a global firm of experts dedicated to applying economic, finance, and quantitative principles to complex business and legal challenges. For over half a century, NERA's economists have been creating strategies, studies, reports, expert testimony, and policy recommendations for government authorities and the world's leading law firms and corporations. We bring academic rigor, objectivity, and real world industry experience to bear on issues arising from competition, regulation, public policy, strategy, finance, and litigation.
NERA's clients value our ability to apply and communicate state-of-the-art approaches clearly and convincingly, our commitment to deliver unbiased findings, and our reputation for quality and independence. Our clients rely on the integrity and skills of our unparalleled team of economists and other experts backed by the resources and reliability of one of the world's largest economic consultancies. With its main office in New York City, NERA serves clients from more than 25 offices across North America, Europe, and Asia Pacific.
About Edgeworth Economics
Edgeworth Economics is a boutique economic consulting firm that provides economic, financial and quantitative analysis for legal disputes and business matters. Our clients include world-class law firms, Fortune 500 companies and government agencies, and we have worked on behalf of Samsung, Google, Bloomberg, and the NFL Players Association. Our expert team of economists, statisticians, and business and human resources professionals offers our U.S. and international clients a diverse background to provide innovative and thoughtful results. At Edgeworth, we know superior analysis must be explainable in a simple, straightforward manner. We take pride in our ability to teach clients, judges, and juries about our research – we work to make the complex simple. And, as a boutique firm, Edgeworth prides itself on being able to offer clients a business relationship attuned to their needs, making our work together an exceptional experience.
About Duff & Phelps
As a leading global financial advisory and investment banking firm, Duff & Phelps leverages analytical skills, market expertise and independence to help clients make sound decisions. The firm advises clients in the areas of valuation, M&A and transactions, restructuring, alternative assets, disputes, and taxation – with more than 1,000 employees serving clients from offices in North America, Europe and Asia.
Investment banking services in the United States are provided by Duff & Phelps Securities, LLC; Pagemill Partners; and GCP Securities, LLC. Member FINRA/SIPC. Transaction opinions are provided by Duff & Phelps, LLC. M&A advisory and capital raising services in the United Kingdom and Germany are provided by Duff & Phelps Securities Ltd., which is authorized and regulated by the Financial Conduct Authority.
To learn more about Duff & Phelps visit www.duffandphelps.com
About Bennett Jones LLP
Bennett Jones LLP is an internationally recognized Canadian law firm, and home to more than 380 lawyers and business advisors in nine offices – Calgary, Toronto, Edmonton, Ottawa, Abu Dhabi, Doha, Dubai and representative offices in Washington, DC, and Beijing. Their professional practice encompasses virtually every sector of business, industry and government.
Their Transfer Pricing practice provides a unified approach to tax and customs transfer pricing for enterprises transferring goods, services and/or intellectual property across borders. Working collaboratively with economists and other transfer pricing consultants, Bennett Jones lawyers seek to maximize transfer pricing benefits for their clients while mitigating risk. Where transfer pricing inquiries or disputes arise, their Transfer Pricing team offers experienced, effective counsel to defend their clients' interests.