Transfer Pricing and Related Areas in a Post BEPS Environment
Quorum Training
Summary
Location & dates
West London
London
W1B1PR
United Kingdom
Great Queen Street
Central London
London
WC2B5DA
United Kingdom
Overview
SPEAKER: IAN WOOD
The OECD’s Base Erosion and Profit Shifting (‘BEPS’) project was launched as a game changer for Transfer Pricing (‘TP’) practice – but expectations are in some areas being scaled back. This course is intended as a comprehensive brief for tax professionals on what has changed (and on what has not changed) in the TP area and in closely related areas such as thin capitalisation, debt deductibility and rules on permanent establishments. It also covers what co-operation is now likely between tax administrations, country-by-country reporting, the Mutual Agreement Procedure and Advance Pricing Agreements as well as the UK’s attempt to ‘go it alone’ – the Diverted Profits Tax.
Description
CONTENT
- The rise and rise of the principal/hub and commissionaire/spokes structure as the dominant TP model in many industries
- How this lead to BEPS
- What is the likely to happen to the TP rule book, post BEPS?
- Tax transparency and country-by-country reporting
- Thin Capitalisation/debt deductibility – the UK as an outlier before BEPS – what happens now?
- Permanent Establishments – before and after BEPS
- Art 25 of OECD Model Treaty – the Mutual Agreement Procedure and Advance Pricing Agreements
- The UK as an outlier (again) – the Diverted Profits Tax
Who is this course for?
Tax professionals who need a thorough understanding of recent changes in transfer pricing.
Questions and answers
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