Event: Transfer Pricing Master Class

July 26 2022 08:30am at Columbia Plaza Venue Center – Limassol
July 27 2022 08:30am at Semeli Hotel – Nicosia

The Cyprus International Business Association, in collaboration with the Cyprus Fiduciary Association, organised two independent 3-hour seminars titled “Transfer pricing Master Class.” 

On Thursday, 30 June 2022 the Cyprus Parliament passed a law introducing detailed Transfer Pricing legislation, marking a new era in company taxation, with effect from 1 January 2022. The OECD Transfer Pricing Guidelines as amended from time to time, have been legislatively incorporated in Cyprus.

Transfer pricing Cyprus deserves to be a top-of-mind priority. The OECD, United Nations, European Union and individual countries have changed and keep changing their guidance in the field of transfer pricing due to the BEPS Project. The new guidance can be considered a game-changer and is expected to alter the transfer pricing outcomes in many situations. This requires a different approach from both tax authorities and multinational enterprises. A significantly more granular risk and functional analysis should be performed. Companies, as well as tax authorities, need to have a better understanding of how value is created concerning the development and exploitation of their intangibles. A further focus is on how companies and tax authorities should deal with the three-tiered OECD approach related to transfer pricing documentation.

The masterclass was specially tailored to the practical needs of transfer pricing professionals working in various industrial and service sectors. The masterclass comprises 4 case studies with respect to:

1. Intra-Group Financial Transactions;
2. Intra-Group Services;
3. Transfer Pricing and Intangibles (e.g. Intra-Group license and R&D);
4. Limited risk distributor. 

By the end of the seminar, the participants were able to deal with all developments in the field of transfer pricing properly and fully understand the transfer pricing principles and methodologies and their practical application. This 3-hour tax training course introduced participants to such principles and methodologies and then covers their application to specific categories of intra-group dealings. 

The course was suitable for practitioners in tax advisory firms, and tax specialists in commerce and industry who regularly encounter issues related to transfer pricing. This was an intermediary/advanced-level course for managers or directors with accounting and law responsibility, including – certified and chartered accountants, lawyers, business consultants, tax advisers, management consultants, audit managers, and financial managers.

The course is suitable for practitioners in tax advisory firms, and tax specialists in commerce and industry who regularly encounter issues related to transfer pricing. This is an intermediary/advanced-level course for managers or directors with accounting and law responsibility, including – certified and chartered accountants, lawyers, business consultants, tax advisers, management consultants, audit managers, and financial managers.

Program

08:30 – 09:00
Registration

09:00 – 10:00
Analysis of the New Transfer Pricing Rules in Cyprus (as of 1 January 2022)
Speakers: Costas Savva, Demis Ioannou

10:00 – 11:00
Masterclass (case study)
1. Intra-Group Financial Transactions;
2. Intra-Group Services;
3. Transfer Pricing and Intangibles (Intra-Group license);
4. Limited risk distributor.
Speakers: Demis Ioannou, Gaspar Lopes Dias, Christos Theophilou, Costas Savva

11:00 – 11:30
Coffee Break

11:30 – 12:30
Debrief of the Masterclass workshop
1. Intra-Group Financial Transactions;
2. Intra-Group Services;
3. Transfer Pricing and Intangibles (Intra-Group license);
4. Limited risk distributor.
Speakers: Demis Ioannou, Gaspar Lopes Dias, Christos Theophilou, Costas Savva

12:30 – 13:00
Q&A Session

The seminar was addressed primarily to all interested professionals that are involved in structuring, taxation and management of companies.

Slides: