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Transfer Pricing - let's get to the point!

Published on 19 Jul 2006 | Took place at Tattersalls Club, Sydney, NSW

Most practitioners understand the concept og transfer pricing but have not hand practical experience in creating transfer pricing documentation. This session aims to give a practical understanding of how to prepare transfer pricing documentation. in particular, practitioners will be provided with a template for building the transfer pricing documentation file.

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Individual sessions

Tying the functional analysis in to common transactions and acceptable methodologies

Author(s):  Doug FONE

Topics covered in this seminar paper include:
 
Classifying the related parties based on function, assets and risks "giving each party a functional description" for benchmarking purposes
 
Tying the classification into how related party pricing is set - for example the use of global price lists.
 
What are the appropriate methoidologies for setting the prices and testing the outcome for:
(i) a local distributor of imported trading stock
(ii) a local manufacturer and exporter of trading stock
(iii) a service providor both inwards and outwards
 
What is the difference between a service and a royality and what methodologies are generally recognized for setting and/or testing the arm's length nature of royalities?

If a foreign compant has a permanent establishment or a dependent agent in Australia, what is the methodology adopted by the PE/agent in dealing with its head office and other off shore related parties?
Materials from this session:

Benchmarking - where do you find data to support your arm's length pricing

Author(s):  Chris BOWMAN

Topics covered in this session will include:

  • What is "benchmarking" in a transfer pricing context - at the time of setting or the time of testing
  • Available public data - ASIC, Business Who's Who, IBIS - but how to filter it?
  • Valid use of overseas data - OSIRIS
  • What are the steps in a benchmarking exercise?
  • How do you make a conclusion linking the chosen data to the client? 
Materials from this session:

Transfer Pricing - creating the documentation

Author(s):  Doug FONE,  Chris BOWMAN

Topics covered in these case studies on transfer pricing documentation include:

  • The ATO TPRR for step checklist for scoring transfer pricing documentation
  • Overview structure and business
  • Financial performance
  • Schedule 25A disclosure
  • A full case study report completed by an expert panel with commentary by the ATO
Materials from this session: