Each session has been based on lectures by experts and followed by discussions and group works based around cased studies and practical examples that requires participants’ active involvement. Participants also elaborated on the issues encountered in their professional practice regarding resolution of transfer pricing disputes existing in their respective countries.
It has addressed the theoretical and practical issues arising
in the resolution and avoidance of transfer pricing disputes. The topics
covered have included administrative and juridical appeals, avoidance of
transfer pricing disputes. The topics were illustrated by case studies and role
plays and Participants presented their countries’ legislation and practices
regarding dispute avoidance and resolution during the event.
Here are the main topics
discussed during the seminar,
- Course
Introduction: objectives, the OECD’s Global Relations programme, overview of
BEPS project, Roundtable, Introductions
- Transfer Pricing
Adjustments / Economic and juridical double taxation
- Unilateral
dispute resolution mechanisms (administrative and judicial appeals /
litigation)
- Bilateral
Dispute Resolution Mechanisms
- Arbitration
(Article 25 (5) OECD Model Tax Convention / EU Arbitration Convention and Code
of Conduct / Arbitration clauses in double taxation treaties)
- Conduct of the
MAP APA Process (APA Request, Pre-filing/Informal Application Stage, Formal
Application, Documentation Requirements)
- Finalization of
the MAP APA (Critical Assumptions, Formal Agreement, Implementation)
- Monitoring,
Renewal and Cancellation of the MAP APA
- BEPS
Actions 13 – TP Documentation, BEPS Action 14 – Dispute Resolution, BEPS Action
15 – Multilateral Instrument in Australia.
