Technical Workshops 2024Monday, 17 June 2024

This Transfer Pricing Principles Primer session is the perfect start to your TP Minds International 2024 learning journey. Developed to provide a solid introduction to Transfer Pricing for those transitioning into a TP-focused role from a general tax background, the session is also an ideal refresher on key principles for those already working in transfer pricing. The main principles and industry dynamics to approach certain crucial areas within transfer pricing benchmarking and the outlook of tax authorities towards it. TP professionals at all seniority levels are therefore welcome to attend and will be catered for. The main topics that we will be covering for this session are:

• Introduction to the basic transfer pricing rules
• Industry landscape within transfer pricing
• Financial transactions benchmarking approaches
• Benchmarking and arms-length computation
  • Practical example:
    - Tangible good transaction
    - Intangible goods transaction
    - Financial transactions
• Q&A session
  

Amount B of Pillar 1 has received relatively little attention, while the merits of Amount A and the intricacies of Pillar 2 have been debated over the last two years. The implementation of Amount B as part of the OECD Transfer Pricing Guidelines in early 2024 has however put the focus back on this important policy. The stated aim of Amount B is to “streamline the process for pricing baseline marketing and distribution activities in accordance with the arm’s length principle.” This workshop will therefore provide an overview of the key concepts of Amount B, look at transactions in scope, the most appropriate method for pricing in scope transactions, documentation requirements and much more besides. Workshop attendees will also have an opportunity to discuss and debate the pros and cons of the unresolved issues, and consider the potential impact for both marketing and distribution operations and for other intercompany transactions not intended to be covered by Amount B.

Given the complex and dynamic nature of today's market, companies are under pressure to tackle the risks of manual processes and meet the growing demand for transparency and compliance in transfer pricing. These challenges mean that focusing on Operational Transfer Pricing (OTP) is more important than ever to stay on top of regulations, increased tax scrutiny, and the need for better visibility. Our workshop will provide an overview of how technology can be used to automate OTP processes from a data-driven perspective. Workshop attendees will also be able to discuss different approaches to OTP and ways to reduce manual workflows and increase efficiency. Participants will gain specific insights into managing data effectively and discover practical examples from Aibidia on automating the P/L segmentation and monitoring to improve compliance and cross-business visibility.

Every year, businesses must navigate an increasingly pressurised, complex and shifting regulatory landscape as part of the annual statutory audit process. Transfer pricing forms a key and often overlooked piece of the puzzle, and has grown further in importance following publication of the Transfer Pricing Records Regulations 2023 on 19 July 2023. For businesses that meet the £200m turnover threshold, HMRC now expects the Senior Accounting Officer to include consideration of the approach to transfer pricing as part of their assessment of the tax accounting controls and procedures. Tax governance isn’t a new concept, but it is an area that is continuing to evolve. With changes in legislation having a growing focus on the importance of data, processes, controls and governance, this workshop will provide practical experiences and insights to help guide your business through these evolving requirements. Members of the wider Grant Thornton network will also be on hand to comment upon and answer questions about their Audit of Tax experiences outside of the UK.