Advanced Transfer Pricing Master-Class Series - Course
- Year of Publication: 2020
- ISBN: 0
Course Duration:
785 minutes
Course Background:
Over the past five months, around 25,000 tax & law professionals have participated in our “thought leadership” webinars, moreover, out of the 2000 Feedback Forms that we sent out to various paid participants, over 40% responses that we received w.r.t the question on “What topics would you like us to deliver for future courses?” was a ‘dedicated, high quality course on Transfer Pricing’.
What shall the course cover?
Against this backdrop, considering that the subject of transfer pricing has substantially evolved since its inception in 2001 from basic, procedural issues (eg. use of multiple year data, computation of arithmetical mean, etc.) to more complex issues (like involvement of intangibles, entity-characterization, attribution of profits to permanent establishments, financial transactions, GAAR, etc.) involving higher stakes, Taxsutra is delighted to present to you an Advanced Course on “Navigating Arm’s Length – A 360 Degree Perspective on Advanced TP Issues” with none other than Renowned Transfer Pricing Expert Mr. Rahul Mitra. Considered among the foremost experts in the field of Transfer Pricing and an ‘original thinker’ on the subject, Mr Mitra have decoded the complex matters in the light of several TP Principles such as, application of TP Methods, dealing with intangibles, BEPS; dispute resolution under advance pricing agreements, litigation; impact of COVID-19, wherever applicable.
In this course, Mr. Mitra has covered an array of topics which includes the following:
| Sr. No. | Broad Topics |
| 1 | Transfer Pricing for contract service providers (including contract and toll manufacturers, contract R&D service providers, etc.), covering issues relating to setting of prices, sharing of risks, whether capacity adjustment is a myth or reality, etc. |
| 2 | Transfer Pricing for selling and distribution functions (limited risk distributors, normal risk taking marketing distributors, entrepreneurial buy-sell companies, etc.), covering issues like selection of transfer pricing methods, marketing intangibles, interplay between custom duty and transfer pricing, etc. |
| 3 | Transfer Pricing for licensed manufacturers, covering issues like supply chain models with respect to the unique regulatory regime of India, marketing intangibles, determination of royalties using profit split method, etc. |
| 4 | Profit Attribution to permanent establishments (PEs), with specific emphasis on dependent agent PEs, project PEs for EPC contracts (covering areas of dispute of offshore and onshore legs of EPC contracts) etc. |
| 5 | Transfer Pricing for financial transactions (covering loans, guarantees, thin capitalisation, etc.). |
| 6 | Interplay between Business Re-structuring, Transfer Pricing and GAAR for outbound structures; and their relevance on CbCR and Master File. |
| 7 | Transfer Pricing for digital economy, covering proposals of OECD under BEPS Action 1 (unified approach under Pillar 1) and United Nations through proposed introduction of Article 12B in its model tax treaty guidelines. |
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
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- Year of Publication: 2020
- ISBN: 0
Course Duration:
785 minutes
Course Background:
Over the past five months, around 25,000 tax & law professionals have participated in our “thought leadership” webinars, moreover, out of the 2000 Feedback Forms that we sent out to various paid participants, over 40% responses that we received w.r.t the question on “What topics would you like us to deliver for future courses?” was a ‘dedicated, high quality course on Transfer Pricing’.
What shall the course cover?
Against this backdrop, considering that the subject of transfer pricing has substantially evolved since its inception in 2001 from basic, procedural issues (eg. use of multiple year data, computation of arithmetical mean, etc.) to more complex issues (like involvement of intangibles, entity-characterization, attribution of profits to permanent establishments, financial transactions, GAAR, etc.) involving higher stakes, Taxsutra is delighted to present to you an Advanced Course on “Navigating Arm’s Length – A 360 Degree Perspective on Advanced TP Issues” with none other than Renowned Transfer Pricing Expert Mr. Rahul Mitra. Considered among the foremost experts in the field of Transfer Pricing and an ‘original thinker’ on the subject, Mr Mitra have decoded the complex matters in the light of several TP Principles such as, application of TP Methods, dealing with intangibles, BEPS; dispute resolution under advance pricing agreements, litigation; impact of COVID-19, wherever applicable.
In this course, Mr. Mitra has covered an array of topics which includes the following:
| Sr. No. | Broad Topics |
| 1 | Transfer Pricing for contract service providers (including contract and toll manufacturers, contract R&D service providers, etc.), covering issues relating to setting of prices, sharing of risks, whether capacity adjustment is a myth or reality, etc. |
| 2 | Transfer Pricing for selling and distribution functions (limited risk distributors, normal risk taking marketing distributors, entrepreneurial buy-sell companies, etc.), covering issues like selection of transfer pricing methods, marketing intangibles, interplay between custom duty and transfer pricing, etc. |
| 3 | Transfer Pricing for licensed manufacturers, covering issues like supply chain models with respect to the unique regulatory regime of India, marketing intangibles, determination of royalties using profit split method, etc. |
| 4 | Profit Attribution to permanent establishments (PEs), with specific emphasis on dependent agent PEs, project PEs for EPC contracts (covering areas of dispute of offshore and onshore legs of EPC contracts) etc. |
| 5 | Transfer Pricing for financial transactions (covering loans, guarantees, thin capitalisation, etc.). |
| 6 | Interplay between Business Re-structuring, Transfer Pricing and GAAR for outbound structures; and their relevance on CbCR and Master File. |
| 7 | Transfer Pricing for digital economy, covering proposals of OECD under BEPS Action 1 (unified approach under Pillar 1) and United Nations through proposed introduction of Article 12B in its model tax treaty guidelines. |
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
