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.Agenda:
- 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
- Services
- Impact of US Services Regulations
- Examples of actual audit questions companies are receiving
- What companies are doing to maximize deductibility of services charges
- Loans
- 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
- Treasurers
- Controllers
- 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 …
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 …
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 …
Course Level:
Intermediate
Advance Preparation:
Print and review course materials
Method of Presentation:
On-demand Webcast (CLE)
Prerequisite:
NONE
Course Code:
134515
NASBA Field of Study:
Taxes
NY Category of CLE credit:
Areas of Professional Practice
Total Credits:
2.0 CLE
2.0 CPE (Not eligible for QAS (On-demand) CPE credits)
Login Instructions:
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SPEAKERS' FIRMS:
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.
Website: https://www.edgewortheconomics.com/
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.
Website: https://www.bennettjones.com/