Please explore upcoming programs or access archived programs below.
Management Services Cost Allocation in a Transfer Pricing Analysis
25 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Shanto Ghosh
Presenters: Rakesh Alshi and Setsuko Fukushima
Increasingly, transfer pricing tax authorities around the world are challenging multinational businesses that provide management services to subsidiaries through a central location and then allocate pro-rated shares of those costs based on a measure of the underlying benefits. How can tax executives be prepared to address these challenges through proper transfer pricing analysis and documentation? We'll discuss:
- The taxonomy of management services from a transfer pricing perspective.
- Reasons behind local tax administrations' disallowing management charges and approaches to enforcement.
- Effective practices multinationals can follow to document the performance, measurement, and allocation of management services.
Explore this complex area of transfer pricing to learn how tax authorities are interpreting transfer pricing laws and ways that you can defend your organization's practices.
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Adapting to Change in Southeast Asia: A Constantly Moving Transfer Pricing Target?
19 March 2013
Host: Stuart Simons
Presenters: Theresa Goh, Roy David Kiantiong, and Thomas McClelland
Most countries in Southeast Asia now have transfer pricing regimes, some which are more mature and others that are relatively new and in early stages of enforcement. How can multinational companies address both ends of this spectrum? We'll discuss:
- Recent transfer pricing regulatory developments in the region, including new rules in Malaysia and updates for Indonesia.
- Practical aspects of transfer pricing documentation requirements across the region.
- Specific issues raised during transfer pricing audits in the region and ways companies have responded.
- Status of the advance pricing agreement programs in the region, including new rules in Malaysia and Vietnam, and lessons learned.
Learn about transfer pricing trends in Southeast Asia and ways to adapt in this changing environment.
Transfer Pricing and Marketing Intangibles: The LG Electronics Case in India
22 February 2013
Host: Shanto Ghosh
Presenters: Richa Gupta, Cam Smith, and Rahul Tomar
The Indian Tribunal recently announced a landmark decision regarding LG Electronics' transfer pricing treatment of advertisement expenses (AMP expenses) of Indian subsidiaries. What could the decision mean for your company? We'll discuss:
- An overview of marketing intangibles and transfer pricing, including their history of tax authority scrutiny.
- How the Indian Tribunal decision lays down certain legal principles, including whether the bright line test can be used to identify excessive AMP expenses and whether excessive AMP expenses can be considered international transactions under Indian transfer pricing regulations.
- Implications of the ruling, including how these principles will be binding for AMP expenses incurred by most Indian entities.
Learn what the latest Indian court ruling means for multinationals with Indian subsidiaries.
Location Specific Advantages: Perspectives from the UN, OECD, and Select Developing Countries
19 February 2013
Host: Shanto Ghosh
Presenters: David Bell and Anis Chakravarty
Tax authorities around the world are paying closer attention to location specific advantages (LSA) and their role in in determining the arm's length price. Should the economic benefit that arises from LSAs accrue to the country where operations are actually performed? We'll discuss:
- What LSAs are and how they are derived.
- Guidance provided by the UN, OECD, and some country regulations.
- How the determination of arm's length price may be affected by LSAs.
- How the UN Practical Manual on Transfer Pricing outlines location rent, and measures available to share location savings between parties.
Explore this fast-growing, controversial area of transfer pricing that is gaining relevance for companies transacting with low-cost jurisdictions.