Transfer Pricing for Services, Cost Contribution Arrangements (CCA), and Intercompany Financing
Date(s) – 14/03/2013
9:00 am – 5:00 pm
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Many taxpayers are now faced with new transfer pricing risks on how to deal with intra-group services, CCA, and intercompany financing transactions. Regarding to intra-group services; on how to find an arm’s length price was substantial, as well as the deductibility of intra-group service expenses had challenged by the qualitative and quantitative aspect regarding whether the service has been rendered or not. Therefore, this seminar will be providing participants an in-depth knowledge on how to demonstrate the identification of services rendered, benefits of the services and it relation to company’s performance since using such services.
Further, since Indonesia Transfer Pricing Regulation has specifically recognized cost contribution arrangements (CCA) between related parties, it may raise an issue regarding tax deductibility in the case of assets, services, and other rights in cost contribution arrangements. Although the tax consequences of a CCA will depend upon whether the arrangement is structured in accordance with the arm’s length principle and is adequately documented; however, there is no detailed guidance on how to keep complies with this regulation. Hence, by follow this seminar, we offer participant an insight in actual operation of CCAs and the standard for determining whether a CCA satisfies the arm’s length principle.
Moreover, as many corporations have intra-group financing transactions involving significant amount, it requires MNEs to establish transfer pricing policies with provide the right answer (arm’s length behaviour) from a tax perspective. This seminar will also examine issues related to transfer pricing challenges presented by intra-group financing and practical ways in dealing with the challenges addressed.
Thursday, 14 March 2013
IDR 2.5 million
• Updated hardcopy material
• Comfort training room and others modern supporting facility
• Certificate of attendance
• Interactive Discussion
• Library access
• Experienced instructor, and
• Snacks, coffee break, and meals