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International Tax & Transfer Pricing for MNEs

Many governments are attacking multinationals on their tax policies, and they become more aggressive by the day. HMRC, for example, even checked Linked-in profiles of employees to support their tax case against Google. The Italian tax police are targeting specific industries and are using brutal tactics. Most business decisions can have a tax impact and everyone involved should therefore be able to understand that impact and how to avoid unnecessary tax exposures. This unique course is taught by a former senior global tax director of a big multinational and former tax law professor. The course is therefore very practical and complex matters will be explained clearly. Many day-to-day business examples will be used to explain the practical tax implications of business decisions. Attention will be given to transfer pricing. Any inter-company transaction is governed by transfer pricing rules. Understanding transfer pricing rules is a must-have for any professional who works in an MNE environment

Turning 'Theory' into 'Practice'?

• The improved tax knowledge will lead to a better understanding of the company’s tax position • Managing the transfer pricing processes and impact better • Improve controlling the company’s tax position • Through better preparing for tax audits you will reduce the resources needed for audit and possible avoid tax penalties and adjustments • Legal professionals will be able to improve the quality of inter company agreements, and will be able to better understand the tax consequences of M&A projects • You will learn how to address globally mobile employees and the tax consequences for the company

Who should attend?

This course is designed for those who work for a Multinational Enterprise in Finance, Legal, Supply Chain, Manufacturing, Marketing or Sales. The job titles include: • Sales & Marketing Controller • Financial reporting specialist, Financial Analyst • Corporate Controller, Financial Controller • Business Analyst • Risk and Control Manager • Legal counsel, Legal director, Corporate lawyer • Marketing manager/director • Sales manager/director • Supply chain specialist • Plant Controller • Regional finance managers/directors

Key areas to be covered in the programme and documentation

Setting the scene
• The current tax climate
• BEPS in practice (Base Erosion and Profit Shifting)
• Transparency in the tax world
• What about tax planning?

Global tax developments
• Switzerland:
• Corporate Tax reform III
• End of the ruling era. What now?
• US: Tax inversions
• Updates on Tax developments from other countries (on demand of course participants)

Permanent establishment (PE) in practice
• The revived tax concept
• Common law versus civil law
• The commissionaire and PE
• Agency structures and PE
• The future of PE according to BEPS
• How to successfully address PE audits

Transfer Pricing
• Transfer pricing risk areas
• Intercompany agreements
• Charging costs intercompany
• Managing the profitability of your group companies
• VAT versus transfer pricing

Year-end adjustments Business model planning
• Manufacturing (from toll - contract manufacturing)
• Sales structures
• Setting up a principal structure anno 2016
• The business model of the future

Transfer pricing compliance
• Transfer pricing documentation
• Masterfile and local country files
• Country-by-Country reporting

The tax director anno 2016
• Challenges
• How tax is managed in MNEs
• How to manage consultants• How to manage tax authorities

Benefits to you

• Minimising your overall tax risks
• Avoiding tax surprises. You will be able to spot potential tax exposures much earlier.
• Getting the useful tips on managing tax audits
• Minimising tax consultancy cost. Through better understanding you do not need to involve tax consultants as much
• Avoid tax penalties

Companies already benefiting include:

Duration of Course

2 Day Course

Course details

Please contact our office at +44 203 002 3057 for any additional information about the course

Looking to train larger teams in this subject?

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Further information

UK Enquiries: +44 (0) 203 002 3057

Non-UK Enquiries: +420 (0)2 5570 7246

North American Enquiries: +1 312 540 3000 X6714 or - Marketing Manager EMEA - Professional Training

UK Enquiries: +44 (0)20 7647 2383 :
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"This course will allow my company to develop its existing strategies to a much greater and hopefully profitable level."

Managing Director, Tarmac