Transfer prices for financial transactions of non-banking subjects

Through practical examples you will learn: how to set interest rates for loans between related parties so that their level can be justified in front of the tax authorities, how to approach interest free loans, what the principles of cash pooling are, when it may be beneficial to agree to it and its most common problems in practice and more on warranties.

Who are the intended participants?

  • Members of management who are setting up or considering changing their entity’s financing on a group level.
  • Tax and accounting specialists who want to gain a better understanding of the tax effects of financial transactions from a transfer pricing and income tax perspective.

Programme

  • How will the BEPS (Base Erosion and Profit Shifting) Action Plan change the view on transfer pricing for financial transactions?
  • In our experience, how do tax administrators approach financial transactions?
  • Interest rates, loans and credits: how to set interest rates, what influences them the most and what sources of information should be used?
  • What is an entity´s credit rating and how does it influence the setting of interest rates?
  • Interest-free loans: the tax authorities´ approach prior to 1 January 2014 and now.
  • Cash pooling: when to agree to it, how to set it up, how to set interest rates. What are its pitfalls?
  • Warranties: what different types are there and is it necessary to pay for the provision or receipt of a warranty?
  • What further effects do financial transactions have on income taxes? Thin capitalisation, application of withholding tax.
  • Actual examples from our practice.

Benefits

After completion of the course, you will be able to:

  • Assess the level of interest rates commonly used on the market (at arm’s length).
  • Defend cash pool models and thus find out whether they would stand up to the scrutiny of the tax administrator.
  • Expose the shortcomings and risks of financial transactions not only from a transfer pricing perspective.
Dates

Transfer prices for financial transactions of non-banking subjects

17. 5. 2018 09:00–16:30
KPMG Česká republika, s.r.o., Pobřežní 1a, Praha 8
Course fee: 5 900,- CZK ex. VAT
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For attending this training course, you are eligible to gain 7 of CPD points.

The fee includes training materials and morning and afternoon refreshments. The training will be conducted in Czech. Members of the Czech Institute of Internal Auditors (ČIIA) are entitled to a 10% discount off the training fee.