Transfer pricing

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This is the agenda for Agenda
Module 1: An introduction to transfer pricing

• 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

Module 2: Understanding your business and its role in the transfer pricing landscape

• 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

Module 3: Transfer pricing methodologies

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

Module 4: Comparability analysis

• Meaning of “comparable”
• Comparability factors
• Comparability analysis
• Comparability adjustments

Module 5: Financial analysis and statistical methods

• Develop an understanding of financial statement issues and considerations
• Understanding financial adjustments
• Understanding profit level indicators
• Understanding ranges and multi-year data

Module 6: Putting it all together

• 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