Complying with international transfer pricing guidelines is challenging at best. Local authorities around the world are becoming much more protective of their tax revenues. International transfer pricing is under increased scrutiny, and non-compliant pricing practices are much more likely to result in tax penalties and significant interference in your business from regulatory authorities. Companies, from the smallest to the largest, need to pay more attention to ensure that their international transactions are compliant with transfer pricing guidelines, robust enough to stand up to increased scrutiny from tax authorities, and are designed to mitigate unintended tax exposures.

1. Ask, Share, Learn – Within the Largest Community of Corporate Finance Professionals
International Transfer Pricing: Is the
Tax Man about to Knock on Your Door

2. • Recognize your company’s existing transfer pricing issues
in the U.S. and other countries
• Identify how to better manage your transfer pricing risks
• Compare your company’s transfer pricing approach to
sample intercompany transactions
• Keep up-to-date with ongoing transfer pricing
developments
After attending this event you will be able to:
Learning Objectives

3. Proformative Event Notes
• Presentation and recording links sent out within
24 hours. PPT already posted at the event’s
landing page.
• Want CPE? Answer all polling questions and
remain for the duration. Questions on CPE
credits? Email cpe@proformative.com.
• Please ask questions for the Q&A at the end of
the event.
• Please take the short survey at the end of
today’s webinar.

4. Introducing Proformative Academy:
• LMS with on-demand video courses taught by senior practitioners
• Over 180 finance and accounting courses - adding a course every day!
• CPE for CPA, CMA, CTP, FP&A, CRMA and CIA
Welcome to Proformative
“Proformative is the leading professional development
resource for every member of the Office of the CFO”
Check it out at www.proformative.com/courses

5. Ask, Share, Learn – Within the Largest Community of Corporate Finance Professionals
International Transfer Pricing: Is the
Tax Man about to Knock on Your Door
Lee Sheehan, Head of Tax Services, Radius
Gianluca Queiroli, Director, Advisory Services, Radius

6.  The Basics of Transfer Pricing
 Price Determination
 Transfer Pricing Questions to Ask Yourself
 Transfer Pricing Questions to Ask Your Preparer
 Additional Considerations
 Corporate Tax Risk Template
 Q&A
Agenda

7. The Basics of Transfer Pricing
Why Transfer Pricing is important?
 Transfer Pricing affects the profits of a
business subject to tax in a particular country.
 Tax authorities have become more aggressive
in monitoring how taxpayers charge for
intercompany services and sale of goods.
 Amazon, Google, Starbucks, but not only …

8. The Basics of Transfer Pricing
What is Transfer Pricing?
 Definition – Price at which an enterprise transfers
(sells) physical goods, intangible property, provides
services to an associated enterprise (related party)
 Associated Enterprises – One of the enterprises
participates directly or indirectly in the management,
control, or capital of the other (ex. Parent/Sub) or the
same enterprises (brother sister companies)
 Arm’s length principle
 FAR (Assets, Assets, and Risks) analysis – base of
comparability in Arm’s length principle

9. Polling Question

10. Price Determination
 TP Methodology for price determination
 CUP
 CP
 Resale
 Other methods
 Cost Plus – goods or services market costs plus
mark-up
 Direct Revenue – Invoicing and collections in the local
country. Revenue all subject to tax locally, minus
deductions for fees paid to associated entity

11. Thank you for your interest in this presentation.
View the on-demand webinar or download the full
presentation at:
www.Proformative.com
EVENT TITLE