Transfer Pricing & the Tax Gap - Current Rules Explained

Introduction

Although the concept of Transfer Pricing is not new it is the focus of increased attention by Revenue authorities and can result in the diversion of substantial resources and costs in terms of a final tax settlement.

The activities of some well-known multinationals have provoked severe responses in terms of the media and public opinion, leading to not only tax issues but also reputational risk. In turn, Parliament has put more pressure on Revenue authorities to deal more robustly with “aggressive tax avoiders”. Inevitably, more companies will find themselves under the microscope. Also for in-house tax teams, this course is designed to bring together the different departments who have an impact on Transfer Pricing, this includes:

• Finance
• Legal
• HR
• Company secretarial

Throughout the course of the day, there will be a series of case studies which look at the impact of Transfer Pricing on different locations in which the business is situated and different departments.

The required documentation in terms of a Transfer Pricing policy and the testing and sample checking that should be done to substantiate the Transfer Pricing policies adopted by the company will also be explored.

The session will also look at the new transfer pricing guidance issued by HMRC in September 2024.

What You Will Learn

This in-person course will cover the following:

• Pricing theory and its relevance to current tax issues
• Risk assessment on Transfer Pricing
• Valid Transfer Pricing data and methodologies
• Documentation required new requirements from April 2023
• The intellectual property aspects
• Building up your defence against Revenue action
• How to conclude a settlement
• Mutual agreement procedures
• Relevant case law
• Interaction with the Diverted Profits Tax