Refresher Course on International Tax and Transfer Pricing

Topics

Speakers

Inauguration - Emerging International Taxation and Transfer Pricing Landscape

Eminent Faculty 

Impact on International Tax – Effect of BEPS:

BEPS Country Implementation - MLI and beyond, India point of view – Interplay between GAAR and BEPS, Tax Dispute Resolution in post BEPS world (Alternate dispute resolution, MAP and AAR), Cross-Border Intra-Group Holding, Financing and IP Structures in a Post-BEPS Environment

CA. Hitesh Gajaria

Current Issues in International Taxation:

Interplay between POEM and PE, Beneficial owner v/s ultimate beneficial owner – Domestic law v/s Tax treaties, Overview of India’s Tax Treaties – Emphasis – Singapore and Mauritius

CA. Jayesh Kariya

Overview of Mergers & Acquisitions - International Tax, Legal and Commercial Aspects

Tax Challenges of Digitalization:

Profit Allocation and Nexus, Minimum Taxes and Taxes on Base Eroding Payments and next steps, Royalty / FTS issues post Artificial intelligence (Machine learning)

Case studies based on recent landmark rulings on International taxation

Fundamentals / Principles of Transfer Pricing and substance in Practice:

Introduction to transfer pricing incl. applicability, Comparability analysis (including Impact due to Covid-19 on comparability analysis), Transfer Pricing Methods - Applying the Arm’s Length Principle – (including Practical challenges in application and acceptance of each method + Future (Profit Split Method), Profit level indicator (PLI), Transfer Pricing Documentation and Form 3CEB (introduction, penalties and issues), Dispute resolutions mechanisms and Approaches to avoiding and resolving TP Disputes, Transfer Pricing Risk Management

Transfer Pricing: Concepts & Issues:

Tested party concept incl. foreign entity as tested party, Deemed international transaction (DIT), Cost contribution arrangements vs. Management charges, Value chain analysis, Typical business models; Captive service providers; full-fledged vs. limited risk distributor; Marketing agents explaining principle to principle vs. Agent relationship through FAR; and Contract vs. toll vs. full fledged manufacturing, Relevance of PE Concept, DEMPE concept of intangibles, APAs, MAP, Safe Harbour (incl. extension for FY 2019-20)

BEPS: The New Transfer Pricing Landscape:

BEPS Action Plans (1, 4, 8-10, 13 and 15), Short and practical update on the latest OECD TP developments – Including Transfer Pricing Post-BEPS

Transfer Pricing and Indirect Taxes-An Integrated Approach

CA. Amit Dhadpale

CA. Neeraj Menon

Case studies based on recent landmark rulings on Transfer Pricing

CA. Anand Jakhotiya 9325444644

CA. Manish Gadia 9820537986

CA. Rakesh Alshi 9819427242