Taxcasts

Sign up

and join Module 1 for FREE!

By signing up, you agree to our Terms of Service, Privacy Policy, GDPR Policy and Cookie Use, and you agree to receive emails from Taxcasts, Inc.

About

Course Structure

Pricing Plans

Member Login

Get Started

A post-BEPS Application

of the Arm’s Length Principle

Online Course

Get geared with the right analytical skills and tools

to effectively address transfer pricing in 2019

Join the Course

Brought to you by

Why TP?

Transfer pricing is one of the most relevant topics in the current international tax environment. Coordinated and unilateral measures undertaken by governments in their efforts to tackle Base Erosion and Profit Shifting ("BEPS") are transforming how companies conduct business across borders.

To help you keep up to date with the developments in this field, we are providing an online, easy-to-access and interactive course experience to get hands on with the application of the post BEPS arm's length principle in practice.

Learning Outcomes

Apply one sided transfer pricing methods in appropriate situations: TNMM, Resale Price, Cost Plus
Identify, address and be able to value intangibles in highly integrated value chains
Apply two sided transfer pricing methods in appropriate situations: CUP and Profit Split
Apply the post-BEPS arm’s length principle to financial transactions and management fees

Who is

it for?

This course is relevant for professionals of all levels of experience, who want to build or broaden their knowledge in transfer pricing. This includes:

Tax and transfer pricing advisors
In-house tax and finance professionals
Government officials
Academics

100% online

Get practical insights with online sessions covering the latest tax developments.

Accessible 24/7 from anywhere

Attend live or complete lectures at your pace. All you need is an internet-connected device.

Interactive

Get a chance to ask questions and interact with speakers when

you attend live.

Course Structure

Module 1

The Arm's Length Principle and One-Sided TP Methods

Date: March 4, 2019

14:00 PM CET

Duration: 1hr 40 min

Q&A: 30 min

What is the essence of the arm’s length principle?

Can you solve each transfer pricing challenge

by applying the arm’s length principle?

What you will learn

The underlying principles of Transfer Pricing
How to derive a classification of an entity from a functional and risk analysis
The key-differences between a routine entity and an entrepreneur
How to translate the abstract classification to specific types of entities along the value chain (i.e. a low risk distributor vs. a fully-fledged distributor)
The crucial importance of the concept and selection of the tested party in transfer pricing

Case Studies

#1 Transactional Net Margin Method (TNMM)

Why the TNMM is so popular
What do you have to consider when benchmarking (step-by-step demo)
How to interpret comparability
What are the hallmarks of a good benchmark analysis and how to utilize an arm’s length range

#2 Resale Price Method (RPM)

Gross margins in transfer pricing
Strength of the “modified” RPM and under which conditions it is applicable

Virtual Tax Events

We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting.

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.

Learn more >

Online Tax Courses

Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!

Learn more >

Module 2

Two-Sided TP Methods

Date: March 18, 2019

14:00 PM CET

Duration: 1 hr 40 min

Q&A: 30 min

Why you have to be extra careful when your analysis encounters intangibles and why you also

take into account the CUP method

What you will learn

How to take account of intangibles in transfer pricing and how to value intangibles
How to deal with intangibles in highly integrated value chains
The factors for the analysis of a profit split
Understanding the importance of DEMPE
Why is it difficult to establish a CUP

Case Studies

Residual Profit Split and Contribution Analysis

Allocation of profits (losses) commensurate with the value added contributions by the respective parties
Understand why a good functional and risk analysis will account for 80% of designing a profit split
Differentiate between processes of high importance and those processes merely reflecting minor value added
Quantify the value added contributions of the respective parties

Virtual Tax Events

We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting.

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.

Learn more >

Online Tax Courses

Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!

Learn more >

Module 3

Applying the Arm's Length Principle to

Financial Transactions and Management Services

Date: March 22, 2019

14:00 PM CET

Duration: 1hr 40 min

Q&A: 30 min

How to address the new developments in financial transactions transfer pricing?

What tools can be used to analyze inter-company transactions?

What you will learn

OECD public discussion draft on the transfer pricing aspects of financial transactions
TP aspects of inter-company loans
TP aspects of cash pools
OECD public discussion draft on Centralized Services
Quo Vadis Benefit Test
How to use safe harbor rules for low value added services

Case Studies

#1: Intercompany Loans and Cash Pooling

Step-by-step survival guides
Pragmatic Excel applications

#2: Management Services

Step-by-step survival guides
Pragmatic Excel application for performing
(and documenting) arm’s length cost allocations

Virtual Tax Events

We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting.

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.

Learn more >

Online Tax Courses

Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!

Learn more >

Meet Your Lecturers

Theo Elshof

Managing Director

Theo Elshof | Quantera Global

Theo is a Managing Director of Quantera Global and has more than 30 years experience in international tax, TP and tax control frameworks in roles as in-house Tax Director, head of the Dutch APA-team, Transfer Pricing director at a Big-4 firm and co-founder of Quantera Global.

His experience includes active participation in competent authority APAs and Mutual Agreement Procedures, design, planning, implementation and defence of restructuring projects, TP controversy / audits, tax and TP control frameworks.

As an industry leader, Theo is a regular speaker at seminars and round tables on global transfer pricing, tax governance and transfer pricing controls and risk assessment. Theo is also a teacher at the Dutch Order of Tax Advisors.

Dr. Oliver Treidler

Founder and CEO

Dr. Oliver Treidler | TP&C

Dr. Oliver Treidler is the CEO and founder of TP&C, a transfer pricing firm based in Berlin, Germany, and an alliance partner of Quantera Global. Prior to founding TP&C, he was a Senior Manager for transfer pricing at Mazars in Berlin.

Oliver has extensive experience in supporting his clients in designing and optimizing transfer pricing structures as well as in conducting comparability analyses and compiling documentation. Oliver subscribes to a pragmatic and business focused approach to transfer pricing. He frequently publishes articles and speaks on current transfer pricing and tax policy issues.

Oliver holds master’s degree in international economics and European studies from the Corvinus University of Budapest (MSc.) and a Ph.D. in economics from the University of Würzburg. He also hold a Certificate as Bachelor Professional of Business Controlling.

Richard Slimmen

Managing Director

Richard Slimmen | Quantera Global

Richard is a Managing Director of Quantera Global and has more than 25 years of experience in international corporation tax and transfer pricing.

His experience includes acting as competent authority in bilateral and multilateral APAs and Mutual Agreement Procedures, designing, planning, implementing and defending complex transfer pricing structures, dispute resolution cases and audits, as well as setting up tax and transfer pricing control frameworks.

As an industry leader, Richard regularly speaks about global strategic transfer pricing risk management and transfer pricing dispute resolution. Richard also lectures transfer pricing at the International LLM Program of Leiden University.”

Included in the Course

Our growing training library

When you become a Taxcasts member, you will get immediate access to our exclusive Tax Library which delivers 45+ hours of training videos, slide presentations, publications, and tax-related resources.

Our collection is constantly growing and includes a vareity of teaching materials that provide easy-to-access, up-to-date and affordable tax learning.

Training videos are organied in short, concept-based clips and cateogrized into topic areas, so you can track your progress and access them anytime via web or mobile.

TP Aspects of Financial Transactions

Learn all about TP aspects of intra-group loans, guarantee fees, captives and cash pooling from a technical and jurisdictional perspective.

PEs and Attribution of

Profits to PEs

Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.

TP Aspects of Intangible Transactions

From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.

TP Aspects of Financial Transactions

Learn how to analyze, price and test related-party financial transactions such as intra-group loans, financial guarantees, captives and cash pools.

PEs and Attribution of

Profits to PEs

Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.

TP Aspects of Intangible Transactions

From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.

Taxation in a

Digitalized Economy

Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.

Worldwide Tax and TP Developments

Watch 10 jurisdiction-based sessionsand annual overviews of global tax developments and tax technology.

Value Chain Analysis

in TP

A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.

Hide

TP Aspects of Intra-Group Loans

Theo Elshof & Arnas Laurynas | Quantera Global

Theo and Arnas give an overview of the recently published OECD discussion draft on TP aspects of financial transactions, with a focus on key transactions covered and their proposed treatment as well as implications arising for multinational businesses.

Specific issues impacting intra-group loans are covered, such as the borrower characteristics, pricing approaches to determining an arm’s length interest rate, etc.

TP Aspects of Cash Pooling Arrangements

Steve Labrum | Baker McKenzie

Steve discusses the TP aspects of cash pooling arrangements, with specific focus on the operation of a physical and notional cash pools, rewards to the cash pool leader and cash pool members, application of the same interest rate for all participants, allocation of cash pooling benefits to the depositors and cash pooling guarantees.

TP Aspects of Financial Guarantees

Gaspar Lopes Dias | Loyens and Loeff

Gaspar covers transfer pricing aspects of guarantee fees. He will cover issues such as explicit, implicit and cross-guarantees, methods in determining arm's length guarantee fees such as the CUP method, yield approach, cost approach, valuation of expected loss approach and capital support method.

TP Aspects of Captive Insurance

Amanda Pletz | NERA Economic Consulting

Amanda provides a technical presentation of TP aspects of captive insurance arrangements. She will kick off with an overview on captives, a look into the OECD discussion draft touching upon these transactions, and lastly offer practical insights on the various methods in determining arm’s length price of captives and pricing of premiums, such as combined ratio and return on capital.

Benchmarking Interest Rates

Kestutis Rudzika & Justinas Laniauskas | RoyaltyRange

Kestutis and Justinas host a hands-on session on benchmarking arm's length interest rates using the RoyaltryRange loan interest rates database.

It includes all aspects to be considered when benchmarking interest rates, such as analyzing the terms and conditions of related party loan arrangement, credit rating analysis, searching for comparable transactions, adjusting uncontrolled transactions for credit risk, tenor, currency risk, country risk, fixed-floating adjustments, etc.

Asia Pacific Perspective

Adriana Calderon & Hong Chuan | Transfer Pricing Solutions

The Transfer Pricing Solutions team offers their insights on the discussion draft as well as on the TP treatment of financial transactions from various jurisdictions across Asia Pacific, namely Australia, Singapore and Malaysia.

Swiss Perspective

Reto Giger & Katja Lötscher | GHM Partners

Reto and Katja share their practical insights of the OECD discussion draft from a Swiss MNE angle - recent TP developments, Swiss WHT implications, thin-cap rules, intra-group balances, interest rate determination as well as cash pooling.

Turkish Perspective

Gökçe Gücüyener | Mazars Denge

Gökçe offers local insights on the TP aspects of financial transactions from the Turkish perspective. Her session includes an overview of intra-group financing, including consideration for other taxes, cash pooling arrangements, guarantee fees as well as the TP treatment of derivatives.

Italian Perspective

Raffaello Fossati | Fantozzi & Associati

Raffaello, a contributor to the comments sent to the OECD Discussion Draft, shares his jurisdictional insights on TP aspects of financial transactions in Italy, as well practical experiences and court cases related to guarantee fees and cash pooling treated by Italian Tax Authorities.

TP Aspects of Intra-Group Financing post BEPS era

Dr. Vikram Chand | University of Lausanne

As the majority of BEPS Action Points directly or indirectly impact financing between group members, revisiting how debt and other financing mechanisms are designed and implemented has become more important than ever. Dr. Chand provides a technical session on the common frameworks for analyzing intra-group financing mechanisms such as inter-company loans, financial guarantees, captive insurance and cash pooling arrangements.

Treatment of Loans in Switzerland and Germany from a TP Perspective

Dr. Peter Happe & Reto Giger | GHM Partners

Peter and Reto from GHM Partners discuss the recent TP developments in Switzerland and Germany respectively, in the context of the BEPS project.

They share their practical experience in tax and transfer pricing treatment of loans in Switzerland and Germany and how recent developments in the international tax landscape are affecting intra-group financing in these countries.

Hide

Taxation of Business Profits and PEs

Dr. Vikram Chand | University of Lausanne

Vikram provides his take on long term policy solutions for taxing digitalized businesses models.

Starting off with an introduction to principles of taxing business profits and PEs under the current tax treaty policy framework, this is then followed by alternatives to the taxation of digital business, namely the introduction of digital PEs.

Discussion on Attribution of Profits to PEs and Digital PEs

Stefaan de Baets & Dr. Vikram Chand | PwC, University of Laussane

Stefaan and Vikram discuss core issues arising in the attribution of profits to PEs and the concept of digital PEs, starting from BEPS Action 7, the AOA, the Additional Guidance on Attribution of Profits to PEs, European Commission’s directive on the taxation of digital PEs and OECD's Interim Report the context of digital PEs.

Attribution of Profits to Fixed Place PEs

Davide Anghileri | University of Lausanne

Davide provides a practical, case-study session on fixed place PEs and attribution of profits to a fixed place PE. Following a background on Article 5 of the OECD Model Tax Convention, he continues with numerous case studies on profit attribution to a fixed place PE.

Attribution of Profits to a Dependent Agent PEs

Piotr Drobnik | Baxter Healthcare

Piotr's session focuses on profit attribution to Agency PEs with several case studies on the role and remuneration of a commissionaire.

This topic is covered as a result of recent changes to the definition of “dependent agent PEs” under BEPS Action 7 and in the context of 2016 and 2017 OECD profit attribution discussion drafts.

Taxation of Digital Business Models

Dr. Vikram Chand | University of Lausanne

Digitization has fundamentally changed the way businesses carry out their activities globally. While the digital disruption has affected almost every area of doing business, it is posing a particular challenge to the international tax framework. Vikram discusses these challenges, and provides his take on taxing digital business models and discusses current approaches in attribution of profits to Digital PEs.

Significant Economic Presence

Pitambar Das | Indian Revenue Agency

Pitambar Das discusses the introduction of the significant economic presence (SEP) test in the Indian domestic tax law applicable to all enterprises, and when non-resident enterprises exceed either a revenue or a user threshold. Pitambar draws from numerous examples and provides his insights on the practical implications for non-resident enterprises in India.

Hide

Intangibles post-BEPS

Kestutis Rudzika | RoyaltyRange

Kestutis talks about OECD BEPS and other developments relating to intangibles. He provides practical guidance on determining the ultimate entity entitled to returns derived from the exploitation of intangibles, and discusses on the importance of DEMPE analysis and how it is amplified by the CbC reporting and other requirements.

DEMPE – Functional Analysis for Intangibles

Kestutis Rudzika | RoyaltyRange

Actions 8-10 of the BEPS framework address the ever-challenging world of intangibles from a transfer pricing perspective. In this session, Kestutis explains how to perform a functional analysis for intangibles. More specifically, he covers the concept of development, enhancement, maintenance and exploitation (DEMPE) of intangibles.

Using the Income Approach to Value Intangibles

Tim Heberden | Glasshouse Advisory

From an international tax professional’s perspective, intangibles and their valuation and treatment for tax purposes have always been challenging tasks. In particular, valuation techniques and their implications from a transfer pricing perspective have been a hot topic in light of the new digital economy and the rise of intellectual property. Tim explains how the income approach can be used to value intangibles using a 7-step process.

Trade Secrets from a BEPS Perspective

Donal O'Connell | Chawton Innovation Services

Trade secrets are included in the definition of intangibles in the OECD BEPS Guidelines as well as 'qualifying IP' in a number of European 'patent box' tax regimes. Donal explains key characteristics of trade secrets and what BEPS developments and several new directives across the US and EU are attempting to address challenges with regulations trade secrets.

Taxation in a

Digitalized Economy

Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.

International Tax

Developments

Watch 10 jurisdiction-based sessions and annual overviews of global tax developments.

Worldwide TP

Developments

From US Tax Reform to TP developments in various countries, stay up-to-date with what's changing in the field.

TP Aspects of Financial Transactions

Learn how to analyze, price and test related-party financial transactions such as intra-group loans, financial guarantees, captives and cash pools.

PEs and Attribution of

Profits to PEs

Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.

TP Aspects of Intangible Transactions

From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.

Taxation in a

Digitalized Economy

Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.

Worldwide Tax and TP Developments

Watch 10 jurisdiction-based sessionsand annual overviews of global tax developments and tax technology.

Value Chain Analysis

in TP

A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.

Hide

Taxation of Business Profits and PEs

Dr. Vikram Chand | University of Lausanne

Vikram provides his take on long term policy solutions for taxing digitalized businesses models.

Discussion on Attribution of Profits to PEs and Digital PEs

Stefaan de Baets, Dr. Vikram Chand | PwC, University of Lausanne

Q&A on Digital Taxation

Tatiana Falcao, Barry Larking & Dr. Vikram Chand

Tatiana, Barry and Vikram jointly discuss on the current trends in digital taxation, unilateral measures, developments at the EU, OECD and UN level. They provide their own unique insights on devising rules that can address taxation issues caused by the digitization of the economy.

Indirect Taxation in the Digital Economy

John McCarthy | Taxamo

Across the globe, tax jurisdictions continue to amend consumption tax legislation — be it a Value-Added Tax (VAT) or Goods and Services Tax (GST) system, and this in response to the unprecedented growth of the digital economy. To comply with consumption taxes instantly and seamlessly, digital solutions are more crucial than ever. John McCarthy from Taxamo is a leading expert in helping digital businesses manage their global VAT/GST compliance and presents how Taxamo’s digital VAT/GST compliance tool helps businesses around the world.

Hide

Anti Tax Avoidance Directive 1 (ATAD 1)

Mazars & Barry Larking

As countries and taxpayers begin to implement the Anti Tax Avoidance Directive I (ATAD) as of 1 Jan 2019, Mazars Germany looks at some of the key aspects of the Directive and together with Barry Larking discuss the implications at a practical level for taxpayers in the EU.

What’s happening in international tax in 2018 and why you need to care

Barry Larking | Taxtube

In a comprehensive session on key tax developments in 2018, Barry addresses questions such as: Do holding companies have a future? How disruptive will digital taxes be? Does the EU Blacklist matter? What about the US Tax Reform and what happened to the MLI? He also gives a sneak peek into the future and what taxpayers need to prepare for in the short and long run.

Transfer Pricing Aspects of US Tax Reform

Ben Miller, PhD | Bennett Thrasher

Ben discusses transfer pricing strategies in managing two significant features of the U.S. Tax Cuts and Jobs Act of 2017 - Base Erosion Antiabuse Tax (BEAT) and the Global Intangible Low Tax Income (GILTI) provisions. He provides specific examples and case studies of how these two measures will impact taxpayers and their tax position in the US.

Implementation in Practice of the PPT in the MLI

Marcus Livio Gomes | University of Rio de Janeiro

Article 7(1) of the MLI contains provisions related to the prevention of treaty abuse, including treaty shopping that correspond to changes proposed in the BEPS Action 6 Final Report.Tax Agreements of many countries include ‘purpose provisions’ with respect to specific benefits, generally royalties, interests and dividends, although there is no ‘catch-all provision’. These provisions might be replaced by the ‘Principal Purpose Test’ provision of Article 7(1). In this session, Marcus discusses the challenges in implementing the PPT in practice and how to overcome them.

International Tax Developments

Key International Tax Developments in 2017

Barry Larking | Taxtube

2017 was a year marked with major developments in taxation around the world. Driven by a world that is ever more globalized, public opinion and governments have taken a serious look at the way current tax systems work and whether they are in need of reforms. From digital taxation initiatives, permanent establishment changes, EU blacklist and US tax reform plans, Barry discusses in detail what these developments mean and their impact for stakeholders around the world.

Hide

Transfer Pricing Aspects of US Tax Reform

Ben Miller, PhD | Bennett Thrasher

Overview of TP Developments in Luxembourg

Filip Vukovic | PwC Luxembourg

In this session, Filip provides an overview of Luxembourg TP developments with a focus on the new Luxembourg IP regime. He also shares his insights on B2B financing structures, the application of the new general TP rules, lessons learnt from the first CbCR submissions, overview of the market and links with the IP regime.

BEPS and TP Developments in the MENA region

Safae Gunneoun | Ernst & Young

Until recently, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing are not high topics on governmental agendas. Safae will cover recent economic trends in the MENA region, as well as the OECD initiative on the BEPS project, which have encouraged governments in the region to adhere to important international tax framework agreements as well as to consider updating their tax legislation in this respect.

TP Developments in the Baltic Region

Vykintas Valiulis | Grant Thornton Baltics

In January 2018, the Lithuanian Ministry of Finance published a discussion draft on the introduction of new Transfer Pricing Rules. Vykintas explains the implications of the new rules such as mandatory preparation of transfer pricing documentation until the 6th month following the financial year-end, for each transaction exceeding 30 thousand EUR, for each entity which total turnover is more than 3 million EUR. He also covers TP developments in Latvia and Estonia and what the future looks like for the region in this area.

Selected TP
Topics

Watch a varied collection of sessions covering topics such as EU State Aid, M&A TP aspects and TP documentation.

Value Chain

Alignment

A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.

Miscellaneous

Check out the latest insights on taxation of cryptocurrencies, tax risk management and international tax career trends from professionals around the world.

TP Aspects of Financial Transactions

Learn how to analyze, price and test related-party financial transactions such as intra-group loans, financial guarantees, captives and cash pools.

PEs and Attribution of

Profits to PEs

Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.

TP Aspects of Intangible Transactions

From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.

Taxation in a

Digitalized Economy

Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.

Worldwide Tax and TP Developments

Watch 10 jurisdiction-based sessionsand annual overviews of global tax developments and tax technology.

Value Chain Analysis

in TP

A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.

Hide

EU State Aid and APAs

Dr. Mario Tenore | Maisto & Associati

Mario discusses recent EU Commission’s investigations on State aid and tax rulings. The EU Commission has taken the view that tax rulings confer a selective advantage upon its beneficiaries insofar as they lead to a lowering of the tax burden by deviating from the tax that the beneficiaries would otherwise be obliged to pay under the general corporate tax system. He illustrates the way in which various decisions released by the EU Commission interpret the OECD TPG.

Automation in Transfer Pricing

John Dar | Intercompany Software

Following BEPS developments which have increased international coordination in the field of transfer pricing, multinationals everywhere face tougher and more complex compliance and disclosure requirements. At the same time, today’s technology enables many business processes to be conducted more efficiently, including here transfer pricing. John discusses how recent trends in technology, such as automation, have changed the way we think about transfer pricing processes and how TP software can help companies execute their transfer pricing policies in a smarter, faster and more accurate way.

Best Practices in TP Documentation and CbCR

Davide Zarecky | TP Tuned

Following BEPS developments which have increased international coordination in the field of transfer pricing, multinationals everywhere face tougher and more complex compliance and disclosure requirements. At the same time, today’s technology enables many business processes to be conducted more efficiently, including here transfer pricing. John from Intercompany Software discusses more about the how recent trends in technology, such as automation, have changed the way we think about transfer pricing processes and how TP software can help companies execute their transfer pricing policies in a smarter, faster and more accurate way.

M&As from a TP Perspective

Arnas Laurynas | Quantera Global

Public pressure, increased transparency and more detailed guidance on Transfer Pricing makes the tax authorities put more and more focus on cross border transactions. What does that mean for M&A deals? How to manage the increased risks? What are expected changes in the way the deals are structured? Are there still tax opportunities on the table as part of the deal? In this session, Arnas discusses transfer pricing aspects that are key in M&A deals and shares his insights on how changes in a post-BEPS world are impacting the M&A process.

Advanced TP Strategies: Resolving 5 Hot-Button Transfer Pricing Disputes

Robert Feinschreiber | Charles River Associates

MNEs worldwide have seen a spike in the number and complexity in TP disputes. Robert reviews 5 hot button TP disputes and covers market concentration and intangible migration, coping with tax haven and foreign trust over-structuring, addressing a production activity that creates multiple distribution chains, how gray marketing impacts transfer pricing, and using the profit split arrangement for loans.

Hide

A Step-by-Step Guide to Value Chain Analysis

Dr. Oliver Treidler | TP&C

Oliver demonstrates how to best utilize Excel tools to simplify analysis and compile consistent and focused transfer pricing documentation. He reviews prominent OECD case studies and illustrates in practice how to conduct a pragmatic value chain analysis.

Value Chain Analysis in Transfer Pricing

Ben Miller, PhD | Bennett Thrasher

In a post-BEPS environment, the concept of value chain analysis has become pivotal. OECD has introduced the value chain analysis as a key basis for setting and documenting transfer prices in accordance with the arm's-length standard. Ben explains their in-house developed 5-step approach to conducting value chain analysis which serves to formalize best practices for transparency and accuracy and effectively advise clients.

Value Creation Analysis under a TP Perspective

Brigitte Baumgartner | TP Baumgartner

The concept of Value Creation has gained a lot of attention from the transfer pricing community in the last year. The inclusion of this term in the new Transfer Pricing Guidelines presents a new challenge for transfer pricing practitioners. Brigitte applies Michael Porter’s value creation approach in a pragmatic way, and offers an alternative to MNEs seeking to align transfer pricing to business strategies.

Hide

Taxation of Cryptocurrencies

Kirk Phillips, CPA

Learn about this ever changing landscape and the gap between new taxable events in cryptocurrency transactions and the regulations needed to support them. Kirk focuses on US taxation, however, defining the unique events in cryptocurrency are universally important regardless of how a jurisdictions applies the respective rules. He answers questions like: What accounting method should be used to calculate capital gains and losses? When is cryptocurrency considered ordinary income vs. capital gain income? Why is cryptocurrency considered property for taxation purposes? What accounting method should be used to calculate capital gain income?

Trends in International Tax Careers

Radomir Graj | Taxjobz

Following the changing tax landscape around the world, it seems that new skills are in demand for tax professionals. The reach of a tax professional’s work is no longer local, but rather global and with wide-reaching impact in the organization they work for. Radomir, a seasoned tax professional and founder of Taxjobz, a fast-growing job board matching tax professionals and multinational corporations and professional firms, provides an overview of the job market for tax professionals and what the trends look like for the future.

Tax Risk Management in the post BEPS era

Karen Holste | TPDG

In light of recent developments in tax disputes of multinationals with governments around the world, implementing a tax risk management framework has become key for many businesses. Karen Holste, expert in tax litigation and tax advisory with in-house and tax authority experience, explains methods, principles and systems to support and manage tax risks and the tax litigation processes cross border to secure cross group alignment on tax audit management.