Date and Time:
June 15, 2023 3:00 PM - 6:00 PM
June 16, 2023 3:00 PM - 5:30 PM
Event Location:
Online, India
Description
Achromic Point presents Advanced 360 Degree Workshop on Transfer Pricing on 15th & 16th June 2023. In this participants will get to know about the Transfer Pricing Policy & Compliance, Transfer Pricing Controversy Management, Transfer Pricing of intangibles & Transfer Pricing – Interplay with other taxes.
Benefits of Attending:
- Understand the transfer pricing process
- Understand Basic principles and terminology and methodologies
- Understand Transfer Pricing Policy & Compliance
- Understand Controversy Management
- Understand how the Labelling of intangibles and Identification of intangibles done
Thought Leaders:
- Vidur Puri
Senior Partner
SCV & Co. LLP - CA. Akshay Kenkre
Founder and Practice Lead
TransPrice Tax Advisors LLP - Abhay Saboo
Partner
Sudit K Parekh & Co. - Mayur Khanna
Principal
Mayur Khanna & Associates
Event Timelines
Session 1: Transfer Pricing Policy & Compliance
• Transfer Pricing policy planning
• Various business models
• Transfer Pricing risks & Tax provisioning
• Annual Transfer Pricing Compliance
o Transfer Pricing Study Report
o Accountants Report
o OECD BEPS Action Plan 13 compliances in India
- Master File
- Country by Country Report
- Practical Considerations
- Penal implications
• Types of Inter-Company Transactions
- List and examples of the most common inter-company transactions
- List and examples of more complex inter-company transactions
- Audit issues, key considerations, and best practices
Session 2: Transfer Pricing Controversy Management
• India TP Litigation Process
• Key Triggers for TP Scrutiny
• Alternate Dispute Resolution Mechanisms
o Advance Pricing Agreements (APA)
o Mutual Agreement Procedure (MAP)
o Safe Harbour Provisions
• Secondary adjustment implications
o India regulations
o International practice
o Practical examples
• Limitation of interest deduction u/s 94B
o India regulations
o International practice
o Practical examples
Session 3: Transfer Pricing of intangibles
• The context of Transfer Pricing of intangibles
• Labelling of intangibles
• Identification of intangibles
• Significance of Development, Enhancement, Maintenance, Protection and Exploitation (DEMPE)
• Ownership of intangibles (legal or economic)
o Overview of Action Plan 8-10 of the OECD BEPS Action plan
o Review of the current transfer pricing landscape and the progress of implementation of recent OECD measures
• Arm’s length analysis of intangibles
o Use of intangible
o Transfer of routine intangible
o Transfer of unique intangible
Session 4: Transfer Pricing – Interplay with other taxes
• Transfer Pricing and Customs Valuation
• GST Aspects in Transfer Pricing
• Transfer Pricing and Section 56
• Interplay with GAAR, SEP, Profit Attribution to PE
• Transfer Pricing and POEM
