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Lecturer: Shiv Mahalingham, Managing Director, Transfer Pricing, Alvarez & Marsal
Transfer pricing compliance can be a costly exercise that requires regular attention and updates. Many businesses, recognising that they possess the necessary expertise, are bringing the preparation of transfer pricing documentation in-house. This workshop is designed to assist that process by running through the requirements for compliance with UK transfer pricing legislation and identifying some risk areas to be aware of. The course is suitable for in-house finance/tax managers and directors who are involved in the preparing of or review of transfer pricing documentation.
PROGRAMME
TRANSFER PRICING – DOCUMENTATION REQUIREMENTS
Overview of UK transfer pricing regulations
Basic documentation structure with reference to OECD, EU and HMRC Guidelines:
- Background
- Industry analysis
- Functional analysis
- Economic analysis
- Conclusions
- Annual reviews
Importance of adopting a risk-based approach
Comparison of international transfer pricing regimes
COMMON RISK AREAS IN PREPARING TRANSFER PRICING REPORTS
- Functional interviews and access to information
- The search for comparables
- Definition of contemporaneous documentation
- Important to assess risk in all relevant jurisdictions
CASE STUDY EXAMPLE TO WORK THROUGH
Information supplied:
- Structure chart
- Notes from a functional interview
- Comparability study
- Draft of documentation
Task: Review the materials provided and:
1. Prepare a list key risk areas in transfer pricing compliance
2. What further information is required?
3. Can you estimate the potential financial impact of any of the risks identified?
4. What other tax risks (non-transfer pricing) should be considered?
Timings: 09.30 - 15.00
Scheduled Course Date
For details of further dates please email info@faculty-one.com
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