Recent Developments in Transfer Pricing, including the Impact of COVID-19 Webinar (1 Hour)

Overview: 

In the aftermath of BEPS, the Tax Cuts & Jobs Act, and the outbreak of  COVID-19, dramatic changes to worldwide transfer-pricing legislation have made old plans obsolete. Each jurisdiction follows a specific set of transfer pricing regulations and guidelines, which are enforced by the local taxing authority. This insightful session provides an overview of current rules, and covers:

  • Methods of transaction pricing
  • Transfer pricing documentation
  • OECD financial transactions guidance
  • Transfer pricing impacts due to COVID-19

Emphasis: 
  • Transfer pricing overview
    – Selecting method to price transaction
    – Best method rule
    – US tax reform
    – The changing landscape
  • Transfer pricing documentation
    – The OECD’s three tiers
       – Country-by-country reporting
       – Master file
       – Local file    
  • OECD financial transactions guidance
    – Intercompany financing
    – Content overview
    – Functional analysis
    – Accurate delineation of financial transactions
    – Debt characterizations considerations
    – Pricing of intra-group loans and guarantees
    – Implicit support—impacts on loans
    – Guaranteed fees: consequences, nature, obligations
    – Key takeaways
  • Transfer pricing in light of COVID-19
    – IP migration/restructuring
    – Intercompany agreements
    – Explaining losses
    – Adjusting intercompany pricing
    – Benchmarking considerations
    – Cash management/financing
    – Tighter budgets
    – M&A/Acquisition Transfer
       Pricing Integration
    – Changes to the Supply Chain

     

Bottom
Prerequisite: 

Basic knowledge of federal taxation and some level of international taxation.

Preparation: 

No advance preparation required.

Level of Knowledge: 

Overview.

CPE Credit: 
1.00
NASBA Field of Study: 
Taxes