Transfer Pricing

(International Taxation)

ATTENTION: Chief Accountants, Treasurers, Administrative Officers, HRD, Business Owners/Employers

Available Webinar Schedule  
16 April 2021 | Friday | 6:00pm-8:00pm

(via Zoom)

 

The most significant international tax issue emerging from globalization confronting tax administrations worldwide is transfer pricing. The dramatic increase in globalization of trade has also led to harmful tax practices that have resulted in tremendous losses of tax revenues for governments.

I. OBJECTIVES AND SCOPE

  • Cross-boarder transactions between associated enterprises

  • Domestic transactions between associated enterprises

 

II.PURPSE OF TRANSFER PRICING

  • Guidelines in applying the arm's length principle for cross-border and domestic transactions between associated enterprises

 

III AUTHORITY OF THE COMMISSIONER TO ALLOCATE INCOME AND EXPENSES

 

IV. TRANSFER PRICING ARRANGEMENT (APA)

 

V. MUTUAL AGREEMENT PROCEDURE (MAP)

 

VI. CONCEPTS OF COMPARABILITY

 

VII. FACTORS AFFECTING COMPARABILITY

  • For goods

  • For services

  • For intangibles

 

VIII. SELECTION AND APPLICATION OF TRANSFER PRICING METHODOLOGIES

 

VIV. DETERMINING OF ARM'S LENGTH RESULTS

 

X. ARM'S LENGTH METHODOLOGIES

  • CUP methods

  • Resale price method used by trading goods

  • Cost plus method used both on selling goods and services

  • Profit based method

  • Transactional net margin method

 

XI. DOCUMENTATION REQUIREMENTS

 

XII. PENALTIES

 

XIII. OPEN FORUM

 

WEBINAR FEE: Php. 2,000.00

(Payment made through bank deposit atleast 1 day [cut-off time: 4:00pm] before the seminar)

(Credit/Debit Card payments are accepted via PayPal)

*Please make all check payments payable to "IPG Training Institute for Professional Advancement"

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