Comprehensive Transfer Pricing

Background:

To enhance the understanding of transfer pricing principles and analysis, as well as its recent developments, hereby, DDTC Academy provides an intensive course program. The curriculum is designed based on reputable international courses and university programs attended by DDTC Academy lecturers. Therefore, this program is also suitable for those who wish to obtain international certification on taxation or related postgraduates program.

The focus of this course is a comprehensive discussion on the Indonesia tax regulation concerning Transfer Pricing, OECD Transfer Pricing Guidelines 2017, UN Manual on Transfer Pricing 2017, the developments related to the OECD/G20 Base Erosion and Profit Shifting (BEPS) project and new model for Transfer Pricing Documentation.

This course is designed for anyone who wish to understand transfer pricing principles and analysis, as well as obtain Advanced Diploma in International Taxation (ADIT) certification. The program is consistently concluded with a written exam referring to the standard ADIT test model held by CIOT, UK.

Topic Covered:

• Introduction, Basic Framework Legal Basis and Trends in Transfer Pricing;
• Arm’s Length Principle, Functional Analysis and Value Chain Analysis;
• Transfer Pricing Methods;
• Comparability and Measurement of Arm’s Length;
• Specific Transactions;
• Compliance Issues and Dispute Resolution;
• Comprehensive Discussion in the Practice of Making a Transfer Pricing Documentation in accordance with the Minister of Finance of the Republic of Indonesia Regulation (PMK-213/PMK.03/2016).