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