Gain an understanding of transfer pricing at our morning seminar
Transfer Pricing implications in relation to intangible and financial transactions
In this complimentary Transfer Pricing (TP) seminar we will explore the major issues faced by taxpayers when it comes to intangible property and intra-group financial arrangements, and what a taxpayer should consider in supporting such transactions.
Most multinational (MNE) groups have intragroup financial arrangements and the amounts involved are often substantial. Debt levels of individual entities can be relatively easily manipulated within an MNE group, and since financing costs are generally deductible and subject to limited or no withholding taxes, the risk to revenue authorities posed by non-arm’s length intragroup financing arrangements can be significant. This risk is arguably increased at the global level through the use of hybrid mismatch arrangements aimed at obtaining relief from tax. Recent research has shown that developing countries are particularly vulnerable to debt shifting and this has led to an increase in TP audit activity by African tax authorities specifically in relation to financial transactions. Thin capitalisation and the resultant interest deductibility challenges are two of the main TP concerns faced by taxpayers.
Intangible property is increasingly critical to value creation and can account for a significant proportion of added value. Many companies have decreased their investment in physical or working capital assets and now focus on developing the company’s brand and other intangible property assets. Understanding the TP aspects of intangibles and the issues that can arise in practice is crucial to ensuring that TP risks are not created (or are minimised) for taxpayers through the non-arm’s length payments for the use or purchase of intangible property or through locally owned or generated intangibles not being sufficiently rewarded.
The TP seminar will touch on the following:
- Identifying intangibles
- Goodwill, going concerns, non-registered IP, registered IP
- DE(A)MPE functions
- Six step process for TP analysis of intangibles
Three steps of analysis:
- Identifying debt versus equity
- Substantiating the quantum
- Determining the interest rate
Space is limited so reserve your seat now!
Date & Time
Tuesday, 19 September 2017