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Transfer Pricing in Multinational Enterprises

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Transfer pricing issues are rapidly becoming familiar. In Japan, the tax authority recently introduced the system that transfer pricing audits are conducted at the same time as general corporate tax audits. Besides, fiscal deficiency of each country brought about by the economic downturn caused by Covid-19 further deepens the transfer pricing problem in which interests conflict with each country.In this class, the students will experience not only the phenomenon of transfer pricing tax enforcement, but also how judgments and calculations are made based on Japanese laws and regulations, using actual cases. In addition, in the class, we will specifically refer to the laws, circulars, administrative guidelines, OECD guidelines, so it will be very useful in actual practice.

Registration deadline:

Please note the following after registration.

Registrants must note that refunds cannot be granted when cancellation notification is received later than four weeks prior to the start date.

Rating4.63

13 reviews
  • Topic

    Accounting

  • Business

    Accountant

  • Position

    Director

  • Fee

    ¥90,000

  • Language

    Japanese

  • Format

    Virtual

Date
09:20〜16:40
09:20〜16:40
Place
Virtual
Registration deadline

Target
Professionals / Almuni

Plan

Day1

  1. What is a transfer pricing problem?
  2. transactions subject to transfer pricing taxation
  3. Intercompany Pricing (Transfer Pricing Methodology)
  4. Typical examples of transactions involving finished goods, semi-finished goods and raw materials
  5. Typical examples of problems in transactions involving patents and know-how

Day2

  1. Typical examples of problems in transactions involving provision of services (donations)
  2. transaction unit issues
  3. Differences from general search (local files, presumptive taxation, retroactivity, etc.)
  4. foreign taxation and global risk management
  5. How to eliminate double taxation (MAP, APA, appeals, etc.)

Cases

  • Original cases created by teacher

Textbooks and reference materials

Text

  • Original textbook created by teacher

References

  • 羽床正秀 編著「移転価格税制詳解」大蔵財務協会(2020)
  • 中里実 他「移転価格税制のフロンティア」有斐閣(2011)
  • 森信夫「移転価格の経済学」中央経済社(2014)
  • 国税庁「移転価格事務運営要領」
    https://www.nta.go.jp/law/jimu-unei/hojin/010601/00.htm
  • 国税庁「相互協議事務運営指針」
    https://www.nta.go.jp/law/jimu-unei/sonota/010625/00.htm

Related

Review

  • Even though I work in a completely different field, I learned a lot about future risks.

    sales 40s Male

  • I think it was a great class, explained in a very easy-to-understand way. I was amazed at how you were able to explain very difficult-to-understand content in such a way that it was so easy to understand and familiar. I learned a lot.

    Independent business 30s Male

  • I was able to deepen my understanding of transfer pricing taxation because the seminar was based on cases, not on detailed interpretations of laws and regulations.

    Professional 40s Male

  • I now understand that transfer pricing taxation is a tax system that few people know about unless they are familiar with international transactions, but it is a very important tax system.

    Management 50s Male

  • It was very easy to understand even though I had no knowledge of transfer pricing, and it also made me aware of the issues.

    Office Worker 30s Female

  • I was able to learn about transfer pricing taxation through the professor's real-life experience that although the textbooks use a simple calculation method, in reality it is a very scary system.

    Tax Accountant Office 20s Male

  • The professor's explanations and class progression were very thorough and easy to understand. I took the course with almost no knowledge of taxes, but the easy-to-understand textbook and lectures made it easy to deepen my understanding.

    sales 30s Female

  • I learned tacit knowledge that can only be learned from practice, and not "mere know-how" to deal with transfer pricing, but "a way of thinking and attitude that can be applied". The explanation of the relationship between law and tax was also very informative. Thank you very much.

    Tax Accountant Office 30s Male

  • As a former IRS career veteran working in the same industry, I found all the information very useful!

    Office Worker 30s Male

  • The heavy subject matter of transfer pricing is not something that is easy to learn, as it is explained mainly through practical experience and field experience, but I believe I learned the kicks and how to approach the subject.

    Office Worker 40s Male

  • I really appreciated the slides that he shared with us in advance for our preparatory study. Transfer pricing was a concept that I first came into contact with in this lecture, and at first it was gibberish to me, but after two days of lectures by the professor, it became clear to me. It was a valuable learning experience for me.

    Office Worker 50s Female

  • The lecture was more practical about transfer pricing, so it was very clear and refreshing to have a clearer understanding of areas that I had not fully understood even though I was actually preparing local files for transfer pricing taxation in my practice.

    Office Worker 40s Male

  • The content was very practical since the professor was involved in the practice.

    Office Worker 40s Male