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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: