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Transfer Pricing and Intellectual Property

Opleiding start op: 19 okt. 2017 00:00

Transfer Pricing and Intangibles, one of today's most important areas of Transfer Pricing!

With the shift towards a more knowledge-based and service-oriented economy, intangible assets such as trademarks, brands, patents, know-how and technology, account for an increasing part of the business value. The accurate and complete taxation and valuation of Intellectual Property (IP) and other intangible assets is therefore essential.

Transfer Pricing and Intangibles: a continuing battlefield

Transfer Pricing and intangibles are one of the most important areas of Transfer Pricing at the moment. General consensus among taxpayers and tax authorities alike is that there is currently insufficient international guidance, in particular regarding the definition, identification and valuation of intangibles for Transfer Pricing purposes. The outcomes of OECD’s project on intangibles are likely to be far-reaching and as such this promises to be the most challenging and ambitious project that OECD have undertaken to date.

What will you learn in the course Transfer Pricing and Intellectual Property?

In this unique distance learning course the authors will look at intangibles from the complementary perspectives of Transfer Pricing and valuation. 

As there is no single definition of Intellectual Property (IP) in use today by tax authorities or the OECD, the authors provide a framework in order to capture the various characteristics of Intellectual Property. Moreover, they discuss the methods that have been provided by the OECD to establish arm’s length pricing or valuation of intra-group transactions of Intellectual Property, as well as the practical implementation of these methods.

Transfer Pricing and Intellectual Property: Target Group

This unique, toplevel distance learning course on Transfer Pricing and Intellectual Property is a must for corporate tax and Intellectual Property legal counsels, Intellectual Property and licensing executives, in-house Transfer Pricing managers, Transfer Pricing advisors, international tax executives, tax directors, accountants, tax inspectors, controllers and CFO’s, tax attorneys and solicitors, CPA’s and lawyers.

Continuing Professional Education (CPE)

It should be noted that the course ‘Transfer Pricing and Intellectual Property’ may qualify for CPE credits, pursuant to the rules of a number of professional associations. Participants are encouraged to check with their professional association to determine eligibility in this respect.

Why a distance learning course on Transfer Pricing and Intellectual Property?

IMF Academy uses distance learning as an alternative and a complement to traditional training methods in order to make course materials accessible to large audiences worldwide. The greatest advantage is to not be confined by constraints such as geographical location and time. Thus, any client, anywhere in the world, can benefit from IMF Academy’s distance learning programs at a time and place convenient to him or her. At the end of every distance learning course, you receive a certificate, acknowledging completion of the course.

Feedback of our Transfer Pricing and Intellectual Property participants

The Transfer Pricing and Intellectual Property course is assessed by participants with a 9.

'Overall a very useful and insightful course. Very clear and easy to understand.'
Mr. C. Kelley, R&D Tax Consultant, Alma CG UK
Sponsorship Opportunities Transfer Pricing and Intellectual Property course
Increase your organisation’s profile to key industry professionals. Position yourself in front of potential clients to showcase your services. To learn more about sponsorship and other opportunities, please contact us.

LESSON I

Transfer Pricing and Intangibles: Introduction

Today, intangible property generally represents between 40-80% of ‘value-add’ of international enterprises (MNEs), making it a key component of an MNEs value chain. Intangible property includes business rights associated with commercial activities, including marketing activities. Intangible property will not always be shown on the balance sheet of a company, and often intangible property attracts a considerable risk, e.g. contract or product liability. 

Given that Transfer Pricing issues pertaining to intangibles are a key area of concern to governments and taxpayers, the OECD found that updating Chapter VI and VIII of the OECD Transfer Pricing Guidelines has become an increasingly important issue in the evolution of new business realities and subsequent adaptations to the Transfer Pricing regulations.

The evolution of the MNE and the importance of intangibles

OECD Definition of Intangible Property

How do emerging jurisdictions (i.e. BRICS) deal with intangibles?

Transfer Pricing and Intangibles: 4 functional variables

Locating Intellectual Property (IP) in tax advantaged jurisdictions

Transfer Pricing Risks (I): Court Cases on Intangibles

Transfer Pricing Risks (II): Corporate Reputation at Risk Through SEC Disclosure of Intercompany Transactions

Questions & Answers

Literature

LESSON II

Intangibles: Transfer Pricing Labels, Identification and Ownership 

Lesson II evaluates the labels that are applied to intangibles in the context of Transfer Pricing by utilizing 4 functional variables. The definitions of intangibles are evaluated from a legal, tax and accounting perspective. The lesson examines methods for applying labels to intangibles and how to properly identify the rightful owners and which entity is entitled to the returns related to an intangible.

Definition of intangibles

Labelling of intangibles

Questions & Answers

LESSON III

Valuation of Intangibles

Lesson III provides a clear picture of the various aspects of assessing the value of an intangible for Transfer Pricing purposes. This is accomplished through providing relevant background information, introducing components of valuation methods and applying the ideas to real world examples of highly valued companies that utilize intangibles in their business models. After introducing these concepts, practical methods of assessing value are examined.

When and why Intangible Assets are valuable

Companies with highly valued intangibles

Why and when are intangibles valued?

Price, Value and Cost   

Generally Accepted Valuation Approaches

Determining the Discount Rate and Capitalization Rate

Business Restructuring and Valuation, Chapter IX, OECD

Questions & Answers

LESSON IV

Business Models: Intellectual Property (IP) Configurations

Lesson IV describes how and where intangibles are located in the value chain of multinational enterprises. This is accomplished through evaluating business models from a general business/commercial perspective as well as from a Transfer Pricing perspective. Case studies and questions to evaluate different practical examples are included in this lesson.

Overview of business models from a commercial perspective

Transfer Pricing and general corporate tax considerations of each model

Model implementation – high level guidance on implementing each of the above mentioned models, including a legal framework for managing Intellectual Property

Case Study

Questions with model answers

Multiple choice questions

Answers to open and multiple choice questions

Literature

LESSON V

Intellectual Property (IP) Law and Transfer Pricing

Lesson V examines the legal system surrounding Intellectual Property rights. The lesson provides a brief history of Intellectual Property rights in the legal context, discusses the future of Intellectual Property rights, and looks at the different types of legally recognized Intellectual Property rights. The lesson further explores on the legal aspects of Intellectual Property exploitation, Intellectual Property management and Intellectual Property transfer. How to protect intangibles through Intellectual Property law, corporate law, contract law and labour law is also examined.

Brief History of Intellectual Property

Future of Intellectual Property

Appearance of Intellectual Property

IP exploitation

IP management

IP transfer

Questions & Answers

LESSON VI 

Accounting definitions of Intellectual Property (IP) and Transfer Pricing

Lesson VI provides a high level overview of the accounting standards relating to intangible assets. The lesson focuses on the recognition and measurement of intangibles according to accounting principles. The lesson examines the differences in valuation of intellectual property according to IFRS, US GAAP and Canadian GAAP.

Introduction – Intangibles

Recognition of Intangibles

Goodwill

Subsequent measurement

Questions & Answers

Literature

LESSON VII

Corporate Income Tax aspects of Intellectual Property (IP) and Transfer Pricing

Lesson VII outlines the corporate income tax aspects related to intangibles and Transfer Pricing. The lesson touches on many tax aspects, including amortization, tax credits, capital gains tax, value-added tax, and more. Several examples from different countries are provided to highlight how intangible property is taxed around the world.

Initial Intangible Asset Value

Amortization/Decrease in the Value of Intangible Assets

R&D Tax Credit

Innovation Box/other Incentives

Replacement Reserve

Withholding Tax on Royalty Payments

Capital Gains Tax

Business Restructuring and Related Taxes

VAT

Purchase Price Allocation

Beneficial/Economic/Legal Ownership

Conclusion

Questions & Answers

Teachers

Your authors/instructors are highly acclaimed Transfer Pricing experts from Transfer Pricing Associates. Transfer Pricing Associates, part of the TPA Global Group, is the leading independent provider of global Transfer Pricing Services. TPA has offices and coverage in over 30 countries around the world and experience in a broad range of Transfer Pricing issues. TPA provides high quality Transfer Pricing advice and assistance to multinationals of all sizes, wherever they are located.

Transfer Pricing Associates and its network partners provide you with high quality tax, Transfer Pricing and valuation services to your company’s intellectual property rights.

The authors/instructors of this toplevel 'Transfer Pricing and Intellectual Property' course are

Steef Huibregtse. Steef Huibregtse is Founding Member of Transfer Pricing Associates. Steef is a member of the Business Advisory Group to the OECD’s Joint Working Group on Business Restructuring. Steef developed both a Global Transfer Pricing Risk Management tool and developed a Global Benchmark Platform. Steef was involved in over 1.000 regional an global Transfer Pricing studies.

Louan Verdoner. Louan Verdoner is Of Counsel at TPA. Louan has special knowledge of the pharmaceutical and chemical industry and exclusive knowledge of business-related Tax and Transfer Pricing issues. Louan worked on numerous business restructuring projects, both as an in-house counsel and as consultant and wrote many articles in the field of Transfer Pricing and general taxation.

Startdata

De cursus 'Transfer Pricing and Intellectual Property' gaat op 19 oktober 2017 en 16 november 2017 weer van start. Op de datum van uw keuze kunt u de eerste les van de schriftelijke cursus 'Transfer Pricing and Intellectual Property' tegemoet zien. Vervolgens sturen wij u elke week een les toe. Aangezien het een schriftelijke cursus betreft, is het ook mogelijk op een ander moment te starten. U kunt uw gewenste datum aangeven op het inschrijfformulier. Voor de bestudering van een lesdeel moet u rekenen op een studieduur van plm. 4 uur. Aan het eind van de cursusperiode ontvangt elke cursist een Certificaat van Deelname.

Prijs / Inschrijven

Transfer Pricing and Intellectual Property, Start: 19 oktober 2017: € 1.980,-
Alle prijzen zijn excl. 6% BTW tenzij anders vermeld.

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Het factuurbedrag (incl. BTW) dient vóór aanvang van de opleiding, echter altijd binnen 30 dagen na de factuurdatum, betaald te zijn.

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