Transfer Pricing: Applying the Arm’s Length Principle in Theory and Practice

This course can be delivered to your organisation as part of our bespoke Corporate Training Solutions, at your own time and your own convenience. Contact us on kla@kpmg.com.mt or call us on +356 2563 6363 or on +356 9963 6363 for more information on how we can take care of your organisation’s training needs.

Course Description:

This session will dig into the OECD Guidelines on the application of the Arm’s Length Principle. It will delve into detail on how to conduct a Comparability Analysis from both Functional and Economic perspectives. Theory will be supplemented with real case studies to provide a better understanding of the two approaches and the steps involved.

Target Audience:

This session is relevant to CFOs, Tax Professionals, CSPs, Accountants and Lawyers.

Learning Outcomes:

OECD Guidelines for application of Arm’s Length Principle
How to conduct a Comparability Analysis:
- Functional analysis
- Economic analysis
The 9-step approach

Prerequisites:

A basic understanding of tax and accounting concepts are useful.

Reading Material:

OECD TP 2017 Guidelines (available for free reading online on the OECD website; against purchase if downloaded)
This session will be covering the below topics:
- Functional analysis step by step (theory & documentation examples)
- Economic analysis step by step (theory & documentation examples)
Prior required reading for each session: slidepack for and OECD TP Guidelines relevant to the session.
Additional reference material would be suggested during each session.
Slidepack for the given lecture will be distributed on the Wednesday prior to each lecture.

Venue: Kindly contact us on kla@kpmg.com.mt to indicate your preferred training method; online or in-person.

CPE Hours: This course qualifies for 1.5 hours of Structured CPE which can be classified as Core Competency. A certificate of attendance will be provided at the end of the session.

Trainer:

Beate Orlova, Manager, International Tax Advisory, KPMG in Malta

Beate Orlova

Beate is an experienced tax professional with specialization in international corporate tax. She also has practical experience and in-depth knowledge in transfer pricing, M&A and due diligence projects. Beate joined KPMG in 2021 and is currently a candidate for a Master’s degree in Finance at the University of Aberdeen. She also holds a Bachelor’s degree from Maastricht University. Following a specialization in transfer pricing, Beate shifted her focus to other international cross-border transactions, and was involved in various structuring, reorganization and due diligence projects, as well as tax risk management. Beate has also presented in several tax seminars in English, Russian and Latvian languages, and she also continues to regularly publish written articles on the current tax topics. Over the years, Beate has enjoyed a very diverse client portfolio and has consulted clients from various industries, including tourism, pharmaceutical, financial, manufacturing and other industries. As a personal interest, Beate closely follows various climate initiatives and actions, with particular interest in sustainable finance.