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Transfer Pricing Fundamentals

Transfer pricing remains today the focal international tax issue facing multinational corporations. Notwithstanding the current uncertainty with respect to the economic climate globally, corporations are nevertheless increasingly crossing national borders to reach new customers, attempt to penetrate larger markets or to lower the cost of doing business.  Any business entity operating in more than one country likely has inter-company transactions involving tangible property, intangible property or services.  

The purpose of this workshop is to provide a brief overview of the complexity of the transfer pricing rules in Canada and the level of documentation that is required to be maintained by any organization involved in related cross border transactions.

Date: November 5 - 6, 2014
Time: 9:00 am - 5:00 pm
Location: 688 Sherbrooke Street West
Fee: $895 CAD plus applicable taxes


Description

In order to optimize its global tax position, proper planning by the organization is crucial.  Prudent consideration is required in properly placing the correct combination of functions, assets and risks in the desired jurisdictions. Understanding the basic underlying principles involved in this complex spectrum is essential in optimizing global after tax profits.

It is vital that any strategic decision involving cross border related party transactions be supported by comprehensive and thorough transfer pricing documentation that incorporates as much evidence as possible in support of an arm’s length consideration.

This workshop will identify and describe the main Transfer Pricing methods used in determining arm’s length prices as well as define their application. 

In addition the workshop will describe and highlight the main ingredients that must be included into an adequate documentation package.  

Finally an overview and interpretation of current jurisprudence on transfer pricing issues will also be presented.


Who Should Attend

This workshop is designed for accountants, lawyers, economists and other professionals who specialize in international taxation who are advising Canadian corporations with existing or planned foreign operations; senior personnel of Canadian businesses responsible for transfer pricing, corporate tax, international tax and/or global taxation; government personnel, dealing with international tax issues and transfer pricing that affect Canadian businesses, as well as students contemplating entering the international tax field.


Objectives

 At the end of this workshop the participants will be able to:

  • Understand the basic principles of Canadian transfer pricing;
  • Differentiate between the different arm’s length methods and their application to specific operating concerns;
  • Understand the Canadian T/P legislative documentation requirements;
  • Become familiar with recent Canadian judicial interpretation on T/P matters of concern.   

Topics Covered

  1. Transfer Pricing framework.
  2. Transfer Pricing Methods (Canada-OECD)
  3. Current legislative and policy trends (Canada-OECD);
  4. Transfer Pricing Canadian Documentation Requirements Overview;
  5. Transfer Pricing Considerations: Jurisprudence “GlaxoSmithKline Canada” and “SNF (Australia) Pty Ltd.”.

Facilitators

Jack Triassi, CPA, CGA is a Tax Consultant and has been teaching taxation at McGill University since 2006.

Mr. Triassi has over 30 years of experience at Canada Revenue Agency where he occupied the following functions: Section manager of Large Case Files; Section manager of International Audit Sector; Section manager of the Business Audit Sector, as well as Section manager of the International Tax sector. Mr. Triassi is a former member of the National advisory steering committee for International Tax Sector; National Risk Assessment advisory committee, as well as the Large Case Files Steering Committee at Canada Revenue Agency.

Mr. Triassi has delivered numerous presentations to the Montreal Tax Executive Institute, Montreal Senior Tax Practitioners and to various CPA firms on topics related to International Taxation, Risk Assessment and Large Corporation.

Santino Di Libero, B.Comm., Adm. A, possesses 30 years of audit experience and over 20 years of experience in the international tax field with particular specialization in transfer pricing case development, as well as the resolution of double taxation cases. Mr. Di Libero is the President of SDL Tax Consulting as of 2009. Previously Mr. Di Libero was engaged as a Senior Director of Transfer pricing at the Montreal office of Gowlings, a major law firm. Working in conjunction with the Firm’s National Tax Practice Group, he assisted clients to optimize their global tax position and reduce exposure to unfavorable audit assessments through proper tax planning and implementation strategies. Prior to joining Gowlings, he was a senior transfer pricing analyst and team leader at the Montreal Tax Services Office of Canada Revenue Agency. 

Mr. Di Libero assisted in the negotiation and implementation of Advanced Pricing Agreements and gained extensive experience and knowledge in international tax areas involving residency, permanent establishment, non-resident property disposition considerations, foreign affiliate issues and tax treaty matters.  Mr. Di Libero has written several articles in International Tax journals and has given numerous presentations on transfer pricing topics to various tax organizations such as the Tax Executives Institute and Canadian Tax Institute.


Cancellation Policy

All cancellation & substitution requests must be made in writing.
Up to 14 days prior to the start date: Full refund
Up to 7 days prior to the start date: Refund minus CAD $100 cancellation fee.
Within 7 days of the start date: No Refund, however suitable participation substitution will be permitted.

If no notice is given prior to the start of the event(s) and you fail to attend, you will be liable for the full course fee.

McGill School of Continuing Studies reserves the right to cancel an event up to 5 days prior to its start.


Contact Information

For general inquiries, contact pd [dot] conted [at] mcgill [dot] ca