The objective of this module is to analyse recently approved legislation regarding transfer prices and swap agreements. This analysis will be done from a clearly practical focus. Said legislation affects both the appraisal of the operations to be carried out as well as the required documentation which must be properly completed. This subject is especially important in terms of providing corporate fiscal consulting services given: the frequency with which assets are transferred or services are rendered between companies within the same business group and between different companies or other associated parties (employees, administrators, partners, etc.); and the significant sanctions contemplated in case companies do not meet said appraisal and documentation requirements.
Duration:
From 20th of January to 24th of March 2011
30 hours
Thrusday from 7.00 to 10.00pm
Price: 1.195€
Module co-ordinator: Professor Valeri Viladrich
The module will be delivered by a faculty group including professionals from the sector and tax inspectors.
Programme: The following modules will be covered during the 9 sessions:
1. Introduction to transfer pricing. The OECD’s role in transfer pricing. The European Union Transfer Pricing Forum
2. Practical application of the arm's length principle
3. Methods of transfer pricing evaluation
4. Economic analysis of transfer pricing
5. Evaluation of intangibles
6. Service problems between related entities. Cost-sharing agreements
7. Spanish transfer pricing regulations
8. Importance of documentation in transfer pricing. OECD recommendations. Code of conduct issued by the European Union Transfer Pricing Forum. Documentation obligations under Spanish law
9. Pre-assessment agreements. Double taxation elimination procedures