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• What is transfer pricing and how does it impact your businesses’ profits, reporting, customs, and taxes?• Introduction to OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations• Arm’s length principle. Introduction to primary source Canadian transfer pricing legislation and guidance, such as adjustments, recharacterization, penalties and contemporaneous documentation
• Introduction to the categories of intercompany transactions (or transfers) including definitions of tangible and intangible property, services, and financial transactions• Impact of global business environment on an entity’s role, risks and profitability• Understanding an entity’s risk-reward profile through analysis of the functions, risks and assets of an entity• Introduction to the types of entities based on role, risk-reward profile and positioning in the value chain
• Traditional Transaction Methods: Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus• Transactional Profit Methods – Transactional Net Margin Method (TNMM), Profit Split• Determination of method to use. Special considerations for intra-group services: management fees, arm’s length charge
• Meaning of “comparable”• Comparability factors• Comparability analysis• Comparability adjustments
• Develop an understanding of financial statement issues and considerations• Understanding financial adjustments• Understanding profit level indicators• Understanding ranges and multi-year data
• Transfer pricing policies• Transfer pricing documentation• Financial statement and other disclosures• Transfer pricing monitoring and adjustments• Canada Revenue Agency audit activity• Country-by-country reporting
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Entering CPA Canada’s Awards of Excellence in Corporate Reporting is simple. Submit your 2016 corporate reporting materials online.
September 18, 2017
Jointly presented by CPA Canada and CPA Ontario, The ONE is the must-attend, multi-track event of the year, designed for all CPAs who want to be at the top of their game.