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 provide a brief introduction and overview of specific transaction types of Transfer Pricing, covering intragroup financing and services, intangibles and business restructuring, mutual agreement procedures, advanced pricing agreements and attribution of profits to permanent establishments. It will also update attendees with the status of the Maltese legislation on Transfer Pricing and on the expected upcoming time-frames of this legislation.

The course consists of 2 sessions which will be covering the following topics:

Session 1: 

• Intragroup financing and the related services
• Intangibles and business restructuring

Session 2: 

• Mutual Agreement Procedure and Advanced Pricing Agreements
• Profit attribution to Personal Establishments

Target Audience:

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

Learning Outcomes:

• Intragroup Financing and Services
• Intangibles & business restructuring
• Mutual Agreement Procedure and Advanced Pricing Agreements
• Profit Attribution to Permanent Establishments

Prerequisites:

A basic understanding of tax and accounting concepts are useful.

Reading Material:

• 2022 OECD TP Guidelines (available for free reading online on the OECD website; against purchase if downloaded)
• This session will be overviewing deep-dives.
• 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.

Trainers:

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

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 holds a Master’s degree in Finance from 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.

Aniket Gupta, Assistant Manager, International Tax Advisory, KPMG in Malta

Aniket is an experienced tax professional with specialisation in International Corporate Tax as well as Transfer Pricing. Aniket is an Associate Chartered Accountant of the Institute of Chartered Accountants of India and also holds Master of Laws in International Taxation from King’s College London and is currently pursuing Advanced Diploma In International Taxation by the Chartered Institute of Taxation, United Kingdom. Aniket has assisted multinationals in multiple industrial sectors in India i.e. energy, logistics, and tourism industry. Following a specialisation in transfer pricing, Aniket shifted his focus to other international cross-border transactions in various structuring and reorganisation projects as well as tax risk management.

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Terms and conditions.