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Transfer Pricing Aspects of Intra-group Financing

  • AFSP
  • CPA (US)
  • EA
  • Tax Preparer
  • CTEC
Transfer Pricing CE Course

1 Credit

$10

Subject Area

Taxes

Webinar Qualifies For

1 CPE credit of Taxes for all CPAs

1 CE credit of Federal Tax for Enrolled Agents ( IRS Approved : GEHNZ ) (Approval No. GEHNZ-T-00758-21-O)

1 CE credit of Federal Tax Subjects for California Tax Professionals (CTEC Approved - 6273) (Approval No. 6273-CE-0701)

1 CE credit of Annual Filing Season program (AFSP)( IRS Approved : GEHNZ )

1 CE credit of Federal Tax for Maryland Tax Preparers (Approval No. GEHNZ-T-00758-21-O)

1 CE credit of Federal Tax for Oregon Tax Preparers (Approval No. GEHNZ-T-00758-21-O)

1 General Educational credit for Tax Professionals / Bookkeepers / Accountants

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Course Description

Transfer pricing for intra-group financing has always been a challenging area of taxation.  Group financing arrangements are increasingly relevant and concerning to tax authorities. Audits regarding intragroup financing have significantly increased.  Solutions to these concerns are still evolving.

The use of third party and related party interest is perhaps the most straightforward profit-shifting technique available in international tax planning. Often referred to as interest-stripping, this base shifting technique is scrutinized by tax authorities globally. In particular, the deductibility of interest expense can give rise to double non-taxation in both inbound and outbound scenarios.

The speaker William Seegar will explain how the fungibility of money creates an opportunity to easily adjust the mix of debt and equity in a controlled entity by considering the following type of intra-group financing arrangements: 

  • Synthetic Credit Rating: Risky or risk-free rates?
  • Intercompany loans
  • Factoring 
  • Cash pooling 
  • Financial guarantees 
  • Performance guarantees
  • Hedging  
  • Captive Insurance

The speaker will also discuss new methodologies that can be implemented in practice, in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted arm’s length principle.

Major topics covered in this online CPE webinar:

  • How the principles of corporate finance bolster practice group financing 
  • The arm's length conditions for treasury activities, including intra-group loans, cash pooling, and hedging.
  • Financial and performance guarantees for intra-group transactions 
  • Substance over form: Recharacterization of debt as equity
  • Group Implicit support and passive association

Learning Objectives

  • To gain a comprehensive understanding of all the pertinent intra-group financing arrangements 
  • To describe how synthetic credit ratings are computed
  • To provide guidance relating to Transfer Pricing Guidance on Financial Transactions and the 2015 Action 4 report on limiting interest deductions
  • To discuss the nature of financial comparable in arm's length analysis of Group financing arrangements. 
  • To recognize the interest cap that limits interest deductions 

Who Should Attend?

  • Annual Filing Season Program
  • Bookkeepers & Accountants & Tax Preparers
  • Certified Public Accountant
  • Enrolled Agent
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Tax Accountant (Industry)
  • Tax Attorney
  • Tax Director (Industry)
  • Tax Firm
  • Tax Managers
  • Tax Practitioners
  • Tax Preparer
  • Tax Professionals
  • Tax Pros