Masterclass: How to correctly apply transfer pricing?

Why not miss it?

Transfer pricing is one of the main sources of controversy between taxpayers and tax authorities not only in Spain, but also worldwide, due to its complexity and subjectivity, as well as the high tax bill that can be generated by the valuation adjustments and the applicable penalties.

It is important that companies know how to properly manage the valuation of their related-party transactions and are aware of the substantial formal obligations to which they are subject.

In this session we will address the essential issues for the proper management of related-party transactions, focusing on those aspects that are most controversial in tax inspection processes.

Sign up for the masterclass: How to correctly apply transfer pricing?

What topics will be covered in this masterclass?

Program:

  • Brief introduction to the principle of free competition, definition of related parties, formal obligations (Masterfile and Localfile, Form 232, Country by Country report and prior communication) and penalties.

  • Verification actions
    • Tax management procedures: specific requirements for Form 232 for failure to file or discrepancies in the transactions declared, and specific requirements to provide documentation (Masterfile and Localfile).
    • Inspection procedures: common development and processes (request for documentation, reconciliation of amounts), regular review of certain operations (management fees, indebtedness, cash pooling, royalties, etc.), and controversial issues in business operations (i.e. segmented accounting, functional analysis, questioning of benchmarking, etc.).
    • Friendly procedures for the avoidance of double taxation (MAP).

  • Previous recommended actions:
    • Preparation of documentation.
    • Definition of compensation policies consistent with the functional analysis.
    • Periodic review and updating of policies.

Speakers

Miguel Hernández Ruiz

Miguel Hernández Ruiz

Senior associate in the Tax Department of Garrigues. He specializes in transfer pricing practice. He holds a degree in Business Administration and Management from the University of Barcelona. He is a regular contributor to Taxand's transfer pricing group.

Javier Delgado

Javier Delgado

Senior associate in the Tax Department of Garrigues. He specializes in the areas of general taxation and transfer pricing. He provides recurring advice to business groups in both areas. He holds a degree in Law from ESADE, a double Master's Degree in Access to the Legal Profession and Business Law and a Master's Degree in Tax Consultancy and Management, all from ESADE.

Technical data

The member companies of amec have a 40% discount on the price and a 20% discount for AER and Ascamm member companies.

  • Price for attending the masterclass:
    • Members amec: 55 € + VAT
    • Members of AER / Ascamm: 70€ +VAT
    • Non-member companies: 90€ + VAT

Minimum number of attendees: 7

amec will not manage the fundae bonus for this training.

Do you have any questions? Send an e-mail to Eva Pahissa – epahissa@amec.es

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