Taxand Global Academy is excited to announce a Virtual Training Tuesday on Business Restructuring: Strategies for managing Transfer Pricing challenges developped in partnership with our Transfer Pricing Focus Group.

This virtual training session will provide our Senior Associates (3+ years of experience) with actionable insights on navigating the intricate landscape of transfer pricing in the context of business restructuring, exploring practical approaches to FAR analysis, risk mitigation, compliance with OECD guidelines, and connections with other tax issues using a case study.

Date: Tuesday 4^th March 2025 – 13:30-15:30 CET – Virtual

Objectives:

By the end of the session, participants will:

• Grasp Key Transfer Pricing Principles in Restructuring:
  • Understand the application of the arm’s length principle and FAR analysis in business restructurings
  • Review OECD guidelines on transfer pricing during structural changes
• Identify and Mitigate Transfer Pricing Risks:
  • Recognize common risks in business restructuring and learn strategies to mitigate transfer pricing disputes
  • Identify and assess other tax issues (aside transfer pricing) resulting from the reallocation of functions, assets and risks
  • Get best practices for compliance and dispute resolution
• Apply Knowledge Through Case Studies:
  • Solve real-world transfer pricing scenarios in restructuring through interactive case studies

Speakers:

• Fabien Billiaert, Partner, Arsene – Taxand France
• Gaspar Lopes Dias, Partner, STI Taxand – Taxand Cyprus

Program (2h):

• Foundations of Transfer Pricing in Business Restructuring
  • Overview of the arm’s length principle and its relevance in restructuring
  • Introduction to FAR analysis (Functions, Assets, Risks) and how they are impacted in restructuring
  • Key insights from the OECD Transfer Pricing Guidelines regarding business restructuring

• Transfer Pricing Risks and Mitigation Strategies
  • Identification of common risks (e.g., profit reallocation, tax authority scrutiny, double taxation)
  • Discussion of real-world cases where restructuring led to transfer pricing disputes
  • Strategies for mitigating risks, including proper documentation and aligning business models with transfer pricing rules

• Compliance and Best Practices
  • Best practices for ensuring compliance across multiple jurisdictions
  • How to document restructurings for transfer pricing audits

• Case Study: Transfer Pricing in a Business Restructuring Scenario
  • Interactive case study where participants will analyze a hypothetical restructuring scenario
  • Group work to determine how FAR analysis applies, how profits should be allocated, analyze tax, transfer pricing consequences, and provide a diagnosis and recommendations
  • Presentation of solutions and key takeaways from the case study

• Wrap-up and Q&A

REGISTER HERE