FL800 – Transfer Pricing for Finance & Tax Professionals

The objective of this course is to introduce students to transfer pricing theory and practice, a relatively new area of international taxation that enfolds high stakes for cross border transactions. The course caters people who wish to build their knowledge on EU tax and competition law: tax accountants, lawyers, and in-house tax and finance employees, government officials. The analysis proposes to set the general legal framework and to engage into understanding the economic and business models involved in a TP analysis, through theoretical and practical illustrative examples. The specific topics analyzed cover areas of interest to Cyprus tax industry, such as intra-group transactions, financial operations, services, and intangibles. These developments have a crucial impact on Cyprus established entities operating as holding companies, or vested with Intellectual Property Rights, and providers of financial and treasury services within the group. The course is a valuable asset for responding to challenges faced by foreign-controlled companies established locally. They relate to the lack of substance and empty PEs tied to the attribution of profits under TP rules. More, the course delivers the tools to operate with sound business methods in the fund industry. It covers intra-group financial services and supplies. It is achieved through the enhancement of the comprehension of TP into financial and assurance transactions. The analysis shall stand as a valuable tool for approaching the most recent Cyprus Tax Authorities circular on TP and financial transactions and sustainably delivering BEPS-proofed services. The course also provides an in-depth mastery of TP and Supply Chain Management and Business Restructurings and EU State Aid. This knowledge is of substantial use for cross-border mergers and acquisitions as well as to legal practice for regulatory authorities and tax professionals.