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In practice, it is virtually impossible to meet all comparability standards in accordance with the arm's length principle. Accordingly, the GECD Guidelines repeatedly state that "transfer pricing is not an exact science", but does require the exercise of judgment on the part of both the tax administrator and taxpayer. Hence to develop a good understanding of transfer pricing principles and mythologies, practical applications in form of case law should give an in-sight on how to deal with issues that are not explicitly covered within domestic legislation as well as the GECD Guidelines.
This course aims to provide participants with an in-sight and alternative view on the application of principles of transfer pricing based on the most important international transfer pricing cases, in view of its application in Indonesia.
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Read more... [Transfer Pricing Case Law (TPC 5)]
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On July 22, 2010 the OECD publicly released the new revised Chapter I - III of its OECD Transfer Pricing Guidelines, along with a new Chapter IX dealing with transfer pricing aspects of business restructuring. The OECD's work on business restructuring has been a hot-button issue for several years with respect to multinational businesses. This course will discuss the most relevant transfer pricing issues to be taken into account when a business restructuring takes place within a Multinational Enterprise (MNE), including the reallocation of profits among the members of the restructured multinational group in accordance with the arm's length principle, more generally, how the arm's length principle applies to business restructurings. Also discussed in this course are permanent establishment issues, which could arise in business restructurings, both in relation to the threshold for recognition of a permanent establishment and to the attribution of profits to a permanent establishment once one is found to be in existence and the potential re-characterization of transactions.
Our course provides participants with an in-depth understanding of the key tax and transfer pricing concepts, methodologies and trends relating to business restructurings.
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Read more... [Transfer Pricing Business Restructuring, Business Strategy, Market & Supply Chain Management (TPC4)]
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The increase in cross border activities has lead to the growing trend of firms to manage their business globally in order to capitalize on economies of scale and operational efficiencies. Often such global operating strategies require the transfer of capital from entities residing in one geographic region to entities residing in another region.
Further, the financial crisis has impacted the real economy. When profit turned into losses, the entities will require funding to keep their operations going. Meanwhile, many favorable financing arrangements have shortly expired; banks are unwilling to provide funding in the current market. As a results many corporation have inter-company financial transactions in place involving significant amount.
This practice, has increased the requirement of multinationals to establish transfer pricing policies to provide the right transfer pricing answer from a tax perspective.
This courses will examine issues related concerning transfer pricing challenges presented by intra-group financing and practical ways in dealing with the challenge addressed.
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Read more... [Intercompany Finance and Hybrid Financial (TPC-3)]
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Intellectual property (IP) is the central resource for creating wealth in almost all industries. The foundation of many commercial companies has shifted from the focus on "hard" capital resources to "soft" capital resources, known legally as IP. In the industrial economy, when the people mention about "capital resources", it will bring to mind balance sheets of cash, or pictures of sprawling manufacturing plants. Those companies that once dominated industries, and now finding themselves that the economy is now driven by companies that do not have anything on their balance sheets, except "soft" capital, which will include such IP as technological know-how, patents, copyrights, and trade secrets.
However, among the most frequently asked questions from the companies is : How much should the company pay for licensing in a technology? Answer: As little as possible from the licensee's point of view. Many entrepreneurs in the industry, however, know that this is really a very complicated question that cannot be answered without a lot of homework. While most companies seem to use a valuation method we would like to call "pulling a number out of the air," there are three primary methods used by licensing professionals to assess the value of IP assets. These are the Cost Method, Market Method and Income Method. With all of these methods, good data and data projection are critical in determining the appropriate numbers.
Through this course, we would like to see how the royalty rate is formed in the practice, especially from the US industry. Much of those royalty rates is a combination of comparability method and analysis method.
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Read more... [Special Course : Licensing Intellectual Property Valuation]
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Intangibles and services are one of the most challenging issues in transfer pricing, both from a theoretical perspective and because of the amount and size involved that may arise in disputes in relation to their recognition and value. Moreover in today's world of knowledge-based economy, transaction involving intangibles an services play an even more significant role in Indonesia, where many technology is mostly imported from foreign developed countries. Followed by substantial rules on how to deal with intangibles and services related party transactions, as issued from the OECD as well as Indonesian domestic transfer pricing legislations, taxpayers are now faced with new transfer pricing risks.
These courses are aimed to prepare participants with the many complicated issues regarding transfer pricing of intangibles and services both from domestic and international perspective. In the end participant should acquire the skills required to deal with these issues in practice.
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Read more... [Transfer Pricing of Intra-group Services and Intangibles (TPC-2)]
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