Transaction involving intangible properties and services between related companies has become high profile targets in recent transfer pricing audits. Many Indonesian enterprises pay a large amount of royalties or services to foreign affiliates, for which tax authorities may consider it as inappropriate from transfer pricing point of view.
Consequently, tax authorities could reclassify the transaction concerned and subsequently impose a correction, usually with an additionally penalty sanction.
This course will address issues relating to transfer pricing on intangibles and intra-group services transactions. The purpose of this course is to subsequently prepare participants for transfer pricing documentation requirements regarding these subjects and to defend challenges made by the tax authorities.
<p align="center"><strong>Course 1:<br /> Transfer Pricing Audit and Defenses</strong></p>
<p align="justify">With the introduction of the self assessment system, taxpayers are expected for an increasing responsibility and compliance by the tax authorities. This objective is being enforced by the tax authorities through its tax audit and investigation programs.<br /> This course examines in detail the trigger factors under which a taxpayer would be selected for such verification activities. More importantly, the taxpayer is given guidance on how he should conduct his affairs even before being audited so as to ensure that errors and weaknesses are minimized. Specific issues in documentation, balance sheet and profit & loss accounts will also be discussed.</p>
<p><strong>Course Material:</strong></p>
<ol>
<li><strong>Auditing Multinationals Enterprises, OECD Perspective: </strong>
<ul>
<li>The Importance of Arm’s Length Principle;</li>
<li> Practical Problems and Issues in Applying TP Method;</li>
<li> Burden of Proof Issues;</li>
<li>Documentation Issues.</li>
</ul>
</li>
<li><strong> Managing Transfer Pricing Audit: </strong>
<ul>
<li> Transfer Pricing Audit Risk Profile;</li>
<li> Transfer Pricing Audit Risk Management;</li>
<li> Effective Transfer Pricing Audit Strategies (Planning, Documentation, Audit Documentation);</li>
<li>Procedure Issues;</li>
<li>Substantive Issues;</li>
<li>Case Studies.</li>
</ul>
</li>
<li><strong> Transfer Pricing Dispute Resolution:</strong>
<ol type="a">
<li>Domestic:
<ul>
<li> Unilateral Advance Pricing Agreement;</li>
<li> Objection and Appeal;</li>
<li> Judicial Review;</li>
<li>Others.</li>
</ul>
</li>
<li> International:<br />
</li>
</ol>
</li>
<ol>
<ul>
<li> Bilateral and Multilateral Advance Pricing Agreement;</li>
<li> Mutual Agreement Procedure (i.e. Corresponding Adjustment</li>
</ul>
</ol>
</ol>
Course 
