1. Book & Pay per Delegate
Workshop on Transfer Pricing –Tax & Regulatory Aspects
Key Take Aways& Benefits:
23rd
January 2015, Hotel Westin (A 5star venue in Mumbai)
One Day Workshop of Executive Coaching to learn measured approach to domestic & International Transfer Pricing
- V4C Professional Training
Booking per Delegate INR 25,000 Net +
12.36% Service Tax.
Table of 3 Pax would get additional 10 %
discount.
Capitalize on the expert knowledge to gain maximum
value on these vital issues:
IMMEDIATELY usable knowledge, skills and methods for enhancing
your Transfer Pricing Policy
UNDERSTAND Regulatory aspects of Transfer Pricing to determine
whether a particular Transaction is , or is not, covered by Transfer
Pricing Regulations
RECOGNIZE how to effectively meet the compliance burden
imposed by the Transfer Pricing Regulations
DISCOVER the secrets to setting your Transfer Prices in a way that
achieves Tax Efficiency without running afoul of the Transfer
Pricing Regulations
IDENTIFY the ways to avoid the most costly mistakes when
establishing and implementing your organization’s Transfer
Pricing Policy
Evaluate whether the transfer prices already set by your
organization are in compliance with the regulatory requirements
PREPARE well for Transfer Pricing disputes with the Tax Authorities
and the resulting litigation
DISCOVER how to save cost on unnecessary litigation in the area of
Transfer Pricing
LEARN about the current state of Law including latest Cases and
Judicial Precedents
Nilesh Patel (US-CPA)
Transfer Pricing Consultant, Trainer and Author of Domestic Transfer Pricing Book
(Founder and CEO)Taxwize
Author of a Book on Domestic Transfer Pricing published by
Taxmann
Ex- Deloitte Transfer Pricing Consultant
Ex- Additional Commissioner of Income-Tax, IRS
Guest Speaker at the Indian Chartered Accountants Institute for their
Intensive Course on Transfer Pricing
Transfer Pricing Trainer for Medium-Sized & LSE Chartered
Accountant Firms in Mumbai
Consultant to listed BSE 100 Corporate Taxpayers on complex
Transfer Pricing issues
Developer of a Software-driven Quiz on Practical Aspects of Transfer
Pricing
Writer of Articles on Transfer Pricing and International Taxation
He have studied Transfer Pricing and International Tax at
University of California, Los Angeles (UCLA). He’s a CPA (USA)
from California Board of Accountancy, and an alumnus of IIT Powai.
Nilesh Patel is a highly experienced Transfer Pricing, International
Taxation and Direct Tax professional. His experience covers the entire
gamut of Transfer Pricing and Direct Taxes. He has worked as an
Indian Revenue Service (IRS) Officer on the post of Additional
Commissioner of Income Tax; as a Tax Executive in a US CPA Firm; and
as a Senior Manager (Corporate Tax) with Deloitte.
Nilesh combines an Engineering Degree from IIT Mumbai with a
Certified Public Accountant (CPA) qualification from the US. He is a
member of the American Institute of Certified Public Accountant
(AICPA) and the California Board of Accountancy.
He has helped clients achieve success in Transfer Pricing – planning,
setting prices, testing prices, benchmarking, compliance, study
reports, and litigation, with success with more than 30 Organizations
in 12+ industries.
On the Training side, Nilesh has designed and delivered 30+ Transfer
Pricing and Corporate Tax Training Programs across industry. His
executive training experience includes analysis of practical issues for
Senior Chartered Accountants and Tax Consultants.
On the Consulting side, Nilesh has led Transfer Pricing and Tax
planning for more than 20 companies and orchestrated change in
Transfer Pricing policy of those companies, including several listed
companies. Nilesh has won more than 15 cases for companies in
Transfer Pricing litigation, appeals and dispute resolution.
Pre Course Questionnaires:
To ensure that you gain maximum benefit from this training, a
detailed questionnaire will be sent to you to establish exactly
where you’re training needs lie. The completed forms will be
analyzed by the course trainers. As a result, we ensure the
course is delivered at an appropriate level and that relevant
issues will be addressed. The comprehensive course material
will enable you to digest the subject matter in your own time.
“Transfer pricing is the leading edge of
what is wrong with Domestic &
international tax”
- Lee Sheppard (Tax Analyst)
Renowned Course Trainer
2. Sessions for the Day:-
Registrations at -8.30 am | Course Begins – 9.00 am | 10.30 –Refreshment Break
11.00 am –Course commences | 1.00 Pm – Networking Luncheon
2.00 pm- Course recommences | 4.00pm – 4.15pm Afternoon Refreshments
5.40 Pm – Course Concludes
Nilesh Patel – CPA (USA), (Former) IRS Officer
Taxwize
SESSION 1: WHAT IS TRANSFER PRICING AND WHEN DO
TRANSFER PRICING REGULATIONS APPLY?
• The program begins right off with a case study to illustrate and
examine when is Transfer Pricing triggered? And what is the Arm’s
Length Principle?
• Concept of Associated Enterprises
• International Transactions covered by Transfer Pricing Regulations
• Domestic Transfer Pricing – change in law from FY 2012-13,
additional transactions covered by Transfer Pricing Regulations
• Case studies on the above topics
SESSION 2: WHAT TO DO WHEN TRANSFER PRICING
REGULATIONS APPLY?
• The prices of transactions between Associated Enterprises have to
be at Arm’s Length - How to determine the Arm’s Length Price?
• Documentation – what to maintain, when to maintain, how to
maintain?
• Transfer Pricing Audit – when and how to file the Audit Report?
• Penalties
SESSION 3: TRANSFER PRICING METHODS
• Six prescribed Transfer Pricing Methods to compute the Arm’s
Length Price
• Practical examples on application of the six methods
• How to select the Most Appropriate Method?
• Benchmarking of intra-group services, transfer of goods, royalty,
and interest payments
SESSION 4: HOW TO CARRY OUT ECONOMIC ANALYSIS
UNDER TNMM (THE MOST POPULAR METHOD)?
• Nine Step process recommended by OECD
• Functions, Assets and Risks (FAR) Analysis
• Selecting the Tested Party
• Searching for comparables
• Relevant filters to select the final set comparables
• Selection of an appropriate Profit Level Indicator (PLI)
• Computation of PLI
• How to make the right economic adjustments to the PLI?
SESSION 5: TRANSFER PRICING ASSESSMENT TRENDS
AND DISPUTE RESOLUTION APPROACHES
• Representing your case before the Transfer Pricing Officer
• How to defend your transfer prices before the Tax
Authorities?
• Preparing for Transfer Pricing assessments, disputes and
litigation
• The approach and thought process of the Tax Department
• Advance Pricing Agreements
• Safe Harbour Rules
• Mutual Agreement Procedure
Why You Should Attend
This one day program is highly interactive, hands-on and based on the
latest knowledge and real world success examples of Transfer Pricing
compliance, planning and litigation. Participants will learn and experience
the program’s multiple subject modules through business simulations;
presentation of lessons learned; case studies; open sharing; sharing of real
world experiences; and development of Transfer Pricing strategy.
This leading edge program is designed for Corporate Finance and Tax
leaders seeking to understand the concept of Transfer Pricing in the
context of meeting the regulatory requirements and achieving tax
efficiency. This one day program is essential for organizations seeking to
lay down an effective strategy for Transfer Pricing. Such a strategy can
achieve tax efficiency; avoid needless disputes with tax authorities; and
curtail litigation.
Your organization daily undertakes business transactions. Without
identifying the transactions that fall within the domain of Transfer Pricing
Regulations your ability to be in compliance with those Regulations is
drastically diminished. This one day program provides you clear and
immediately applicable knowledge and skills regarding the “What?”,
“Why” “When” and “How” for the critical aspects of Transfer Pricing
compliance and management. Attending this program will equip you to
save tax as well as the cost on unnecessary litigation in the area of
Transfer Pricing.
Who should attend?
President, Vice President, Director, Head, Chief, Senior Manager,
Manager and Heads of:
Tax
Finance
Accounting
Company Law Compliance
Company Secretary
From: Sectors
All Sectors of Industry
Computer Software and Hardware
Pharma and Healthcare
Cement/Manufacturing
FMCG/Electronics
Oil and Gas
Government Agencies
Real Estate/Construction/Infrastructure
Capital goods
BFSI
Question & Answers Sessions before End of Day
As the program draws to a close there will be a free-flowing Question and
Answer session. Here attendees can address their specific experience and
questions, with responses coming from the program leader and fellow
delegates.
Learning Logs
The Day will wrap up with attendees taking time to enter their key learning
from the Day’s activities. Such recording of “lessons learned”, possible places
for applying the Day’s ideas and/or new questions for further exploration - all
these, it is proven; enhance learning and the program’s benefits.
3. Few Testimonials
“Transfer Pricing, both International and Domestic, is the one of the prime concerns of Corporate Tax and Finance Managers and its importance keeps
growing with each passing year. Sound knowledge of Transfer Pricing concepts, rules and processes is now a must for everybody wishing to work in the
fields of Corporate Finance and Tax, either in Industry or in Practice. Mr. Nilesh Patel is an ideal Professional from whom one can learn all practical
aspects of Transfer Pricing.”-Vineet Agrawal, Senior Vice President & Group Head (Taxation), JSW Group
“As a thorough Transfer Pricing Professional, Nilesh Patel represents our Business Group i.e. Glenmark Group, before Transfer Pricing Officer as well as
before Transfer Pricing Appellate Authorities. His approach is very systematic and professional. His written and verbal submissions before Transfer
Pricing Authorities have helped us in getting dispute-free Assessment Orders. I highly recommend this very useful Course on Transfer Pricing to all
aspiring Professionals.” -Sunil Sultania, General Manager Finance, Glenmark Pharmaceuticals Limited.
"Nilesh Patel is a thorough Transfer Pricing and Corporate Tax Professional. He will leave no stone unturned to ensure that the participants are
empowered to work confidently on real Transfer Pricing Assignments. All professionals associated with Transfer Pricing and all professionals thinking of
associating with Transfer Pricing, must avail of this opportunity.
It is no secret that Transfer Pricing has already become one of the most important subjects in Taxation and it is further growing in scope and potential as
a rewarding area of practice and career.“ - Vikram Sankhala, Financial Consultant, V2Solutions
“I have attended two Transfer Pricing training sessions conducted by Nilesh Patel: one was during 'Intensive Course on Transfer Pricing' organized by
ICAI-WIRC and the other was on 'Domestic Transfer Pricing' organized by a well-known CA Firm in Mumbai. The study material provided by him and the
practical knowledge delivered were of high professional standards. He freely shared his deep knowledge of Transfer Pricing and explained various
concepts by drawing real life examples from his rich and varied experience. Speaking from a position of knowledge and experience, Mr. Patel makes sure
that the knowledge gained reflects in the value of your learning effort to your organization.” –Ajay Dave, Chartered Accountant Association,
Mumbai
“I got the opportunity to work under Nilesh Patel on Transfer Pricing and Direct Tax litigation cases in the early days of my career as a Tax Professional.
Working with him was a great learning experience. Nilesh Sir is a natural Teacher and Guide. He not only helped me in understanding the complex tax
laws but also provided insight on practical issues faced by a professional in this field.” - Gautam Gupta, Deloitte
We regularly consult Nilesh Patel while working on our Transfer Pricing Assignments. Under his guidance we have prepared several Transfer Pricing
Study Reports for our clients. He also advises us on making effective representations during hearings before Transfer Pricing Officers. Nilesh Patel acted
as our Trainer earlier when we had newly entered the field of Transfer Pricing.- Nikesh Jain , JMR Group
Few Clients Story (Organization’s Confidential)
Case 1: Listed Indian Pharma Company transferring a pharma molecule to its Swiss Subsidiary was facing Transfer pricing Issues
The Result: There was no Transfer Pricing Adjustment; the Client was saved from the pain of unnecessary litigation.
Case 2: A US Software Company having a Subsidiary in India was facing issues on appraisal of business operation and was asked to
pay surprise Tax
The Result: The Transfer Price of services rendered by the Indian Software Company to its US Parent Company were
calibrated at Arm's Length Price; and the Client saved Rs. 12 Crores
Case 3: An Indian Company in Logistics Industry expanding its business to the US and Singapore hence significant part of
resources used for expansion was frittered away in resolving Transfer Pricing and Tax issues. That is why Transfer Pricing and Taxes
remain vital areas of concern for Corporate.
The Result: Trouble-free business expansion without Transfer Pricing and Tax problems.
V4C Training Format:
• Pre-course questionnaires.
• An in-depth tailored program to address market concerns.
• Comprehensive course documentation.
• Interactive roundtable discussions and breakout sessions.
• Practical exercises International and Local case studies.
• Opportunity to network with an internationally recognized trainer.
Register Now
Contact Sales at V4C Trainings & Conferences
Tel: +91 22 66739050 / +91 9029293666
Email- : training@v4c.co.in
: training@v4c.co.in
V4C Training & Conferences reserves the right to change the venue of, or speakers at the conference should circumstances require.
4. Workshop on Transfer Pricing –Tax & Regulatory
23rd
January 2015, Hotel Westin (A 5star venue in Mumbai)
VC-5603 Please write In BLOCK LETTERS
- V4C Professional Training
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Register now
Contact Sales at V4C Trainings
Tel no: +91 22 66739050 Cell no: +91 9029293666
Email: training@v4c.co.in
Date: 23rd January 2014 (Mumbai)
Venue: Hotel Westin (A 5star venue in Mumbai)
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