Advanced Transfer Pricing Strategies. |

About Event

“Overview”

Globally fight against against tax evasion is at its fill swing and tax authorities of different jurisdictions are amending there local tax laws to take care of the same. In line with internationally accepted measures, and being signatory to Base Erosion and Profit Shifting Action Plan of OECD, India has introduced various transfer pricing measure to ensure MNEs operating in India do not shift taxable profit. Thus it has become although more important for such MNEs to have robust internal transfer pricing framework to avoid or minimise future litigation. By attending this event, tax heads, managers and professionals would be able to develop insight into new transfer pricing rules and compliances which will go a long way in developing strong internal transfer pricing framework.”

About Your Faculty

Hans de Kruijs

Hans has more than 25 years experience in providing tax planning and structuring services to MNE’s, as well as individuals taking up assignments in the Netherlands and overseas. Previous experience includes Crowe Horwath International, where he worked as International Tax Director and managed cross border tax assignments involving multiple countries and areas of tax, including corporate and personal income taxes, VAT and payroll taxes. He has worked in New York and Amsterdam (current location). Hans is a member of the Dutch Order of Tax Advisers (NOB) and actively involved in public speaking and presenting on tax subjects internationally. Hans has a degree in fiscal law from the University of Leiden. Hans a strong experience in Controlling and supervising regional tax groups in Asia-Pacific, Europe, Africa & Middle East and the Americas.
He has advised on cross border expansions and acquisitions, transfer pricing issues, disposals, joint ventures, corporate reorganizations and was actively involved in tax optimization and compliance projects covering a variety of sectors including IT and telecommunications, real estate, manufacturing, oil and gas, distribution, media and sports.
His technical skills include company ownership optimizations, analysis of double tax treaties and EU regulations, corporate and withholding tax aspects of business restructuring, APA’s and dispute resolution.

Gaurav Garg

Founder and Director of JGarg Economics Advisors Pvt Ltd, Delhi based niche transfer pricing and GST consulting practice. Gaurav is a qualified chartered accountant with more than a decade of full time experience in transfer pricing. Before starting JGarg in 2009, for almost 5 years, his transfer pricing skills with one of the Big4 accounting firm. He is faculty for the certificate course on international tax conducted by the Institute of Chartered Accountants of India and is regular speaker on the subject at various platforms including Confederation of Indian Industry, PHD Chamber of Commerce, Chamber of Tax Consultants and Taxsutra. Gaurav has worked on more than 600 transfer pricing assignments and has clients operating in different industries.
Till now, he has delivered more than 150 lectures on transfer pricing and GST. He has also been invited to deliver talk shows on National New Channels – NDTV 24X7 & JK 24X7. His client list includes Indian listed companies and multinational companies operating in India. In addition to India, recently, he also been appointed as Tax Director for two upcoming tax consulting firms in UAE.
• Director Tax – Brancos Consulting FZ LLC, Dubai
• Director Tax – Expert Tax & Accountants Consultants LLC, Abu Dhabi
• Focus area – Transfer Pricing and Goods & Services Tax
• Founder – Federation of Tax & Accounting Professionals
• Faculty – Diploma in International Taxation offered by ICAI
• More than 13 years of experience in transfer pricing and international taxation
• Worked for approx 5 years with Big4 accounting firm
• Delivered more than 150 lectures so far on issues relating to Transfer Pricing and Goods & Services Tax
• Member of ICAI since 2004
• Bachelor’s degree in Commerce from Sri Guru Gobind Singh College of Commerce, Delhi University
• Special Invitee in FY 2011-12 – The Committee on International Taxation of the ICAI
• Regular contributor to professional journals

Join us on 6th – 7th February 2018 Mumbai

Register Today

1. Session One

Principles of international taxation;Principles of international taxation;

• Role and structure of double tax treaties

• Residence and substance concepts

• Methods of relief from international double taxation

• Transfer pricing and thin capitalization rules

•Indirect taxes and international taxation

• Dispute resolution regime

2. Section Two

Basic Tax Planning Schemes;Basic Tax Planning Schemes;

• Holding companies

• Role of the Netherlands in international tax planning

• Participation exemption

• Innovation Box

• IP right structuring

• Investment schemes

•Employment/expat facilities

3. Section Three

Global Transfer Pricing Risk ManagementGlobal Transfer Pricing Risk Management

• Additional compliance burden and a higher demand for the time spent by (in-house) Tax & TP teams on TP planning and documentation

• Role of economic substance in your intercompany pricing

• Whether three realities, i.e. legal, financial and economic, are aligned

• How to set up a TP control framework?

• Who is responsible for the TP control framework?

• How to make the TP control framework as part of the business control framework?

4. Section Four

Value Chain Analyses (VCA) post BEPS.Value Chain Analyses (VCA) post BEPS.

• How does BEPS relate to VCA?

• Interaction of BEPS and tax

• History of VCA

• VCA definition

• VCA techniques

• Tax technology

• Controversy management

5. Section Five

Increase your chances of survival in battles with tax authoritiesIncrease your chances of survival in battles with tax authorities

• Be aware of and prepared for resolving such disputes in a methodical and timely manner.

6. Session One

Transfer pricing documentation and country by country reportingTransfer pricing documentation and country by country reporting

• Objective and applicability of Three Tier Transfer Pricing Documentation

• Understanding Three Tier Transfer Pricing Documentation

• Master file

• Local File

• Country by Country Reporting

• Comparison of current reporting framework with the proposed framework

• Understanding reporting requirement under Indian transfer pricing regulations

• Penalty provisions

7. Session Two

Secondary Adjustment – New Missile in Transfer Pricing Arsenal Secondary Adjustment – New Missile in Transfer Pricing Arsenal

• Meaning of secondary adjustment

• Methods for applying secondary adjustment

• Approach to be followed as per Indian Income Tax Act

• Practical instances on which secondary adjustment may arise

• Practical challenges encountered

8. Session Three

Aligning transfer pricing outcomes with value creation (BEPS Action plan 8-9-10) Aligning transfer pricing outcomes with value creation (BEPS Action plan 8-9-10) Intangibles

• Meaning and significance

• Legal Ownership Vs Economic Ownership

• Process for identifying the commercial or financial relation in relation to intangible

• Guidance for transactions involving the use of intangibles

• Valuation of Intangibles

9. Session Four

Intra group servicesIntra group services

• Meaning

• Issues encountered in relation to Intra group services

• Understanding benefit test analysis

• Understanding shareholder cost, group cost, duplicate cost and incidental benefits

• India’s position in UN Manual

• Valuing intra group services

10. Session Five

Cost contribution arrangement (“CCA”)Cost contribution arrangement (“CCA”)

• Meaning of CCA

• Who are participants of CCA?

• How to determine expected benefits from CCA

• Balancing payments

• Case studies for extensive analysis

11. Session Six

Transfer pricing litigations recent trendsTransfer pricing litigations recent trends

• Judgments on key issues in transfer pricing in the recent pastWhat to expect ahead

Schedule

Registration

8:00 am - 8:30 am

Morning Session Begins

9:00 am

Tea Break

10:30 am - 11:00 am

Morning Session Continues

11:00 am

Lunch

1:00 pm - 2:00 pm

Afternoon Session Begins

2:00 pm

Afternoon Refreshment & Networking

3:30 pm - 4:00 pm

Closure

5:30 pm

Key Topic to be Covered

Who Should Attend

Who should attend:
CFO’s, Directors, GM’s, Managers of following functions:
Taxation,
Accounts
Risks
Funds management
Financial operations
Regulatory
Legal
Transfer pricing

From following industries:
Trade & Industry,
Government,
Public Sector Units,
Consultancy Organizations, like practicing CA, CS, CMA
Funding Agencies,
Corporate Lawyers,
Banks
Financial Institutions
Non banking financial institutions
FMCG
White goods
Heavy engineering
Export & import
Mining and metals
Natural resources
Oil and gas
Telecom

Pricing

Package	Delegate	Standard Rate
Hard Copies & Soft Copies of Training Materials,Certificate of AttendanceBreakfast,Lunch,Evening Snacks	Indian Companies	35000 INR + tax per delegate

*Additional GST of 18% is applicable.