Transfer pricing of intercompany transactions

By the end of the training, participants will be able to:

• define the transfer pricing reporting obligations that are applicable for Cypriot tax resident persons and permanent establishments of foreign entities
• explain the main principles of transfer pricing
• choose the applicable transfer pricing methods to various transactions between related parties
• apply internal transfer pricing mechanisms for transactions between related parties
• implement different approaches to transfer pricing analysis
• encourage transfer pricing reporting compliance at a company or group level
• juxtapose possible transfer pricing models for particular intercompany transactions.

The training is addressed to employees of tax and finance departments such as internal Tax professionals, CFOs, finance managers, directors, accountants and other professionals, who wish to enhance their knowledge of transfer pricing analysis and understand the importance of establishing arm’s length prices for intercompany transactions.

*The number of participants is restricted to 28.

1. Introduction (1 hr)

Key principles of transfer pricing: Cyprus legislation and Organisation of Economic Cooperation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

• Arm’s length principle
• Transfer pricing methods
• Transfer pricing reporting in Cyprus

2. Transfer pricing in services transactions (1 hr)

• Functional analysis
• Applicable transfer pricing methods
• Low value-adding services and benefits test
• Allocation of costs

3. Transfer pricing in transactions involving intellectual property (1 hr)

• Development, Enhancement, Maintenance, Protection, Exploitation (DEMPE) functions
• Applicable transfer pricing methods
• Economic analysis

4. Transfer pricing in financial services transactions (1 hr & 30 min)

• Estimating credit rating of a borrower
• Adjusting credit rating for group membership
• Analysis of loans
• Lender’s and borrower’s perspective
• Analysis of financial guarantees

5. Preparation of Cypriot transfer pricing reporting (1 hr)

• Table of summarized information
• Local file
• Master file

6. Summary & Discussion - Questions & Answers (30 min)

If you wish to register for the seminar, please complete the registration form.

Once your registration is submitted, you will receive an email stating the participation fee, including any discounts, if applicable. Kindly note that the payment should be settled at least two days prior to the seminar’s date for your registration to be confirmed.

The programme has been approved by the HRDA. Enterprises participating with their employees who satisfy HRDA’s criteria, are entitled to subsidy. Please note that there are limited seats available, therefore enroll in this seminar as soon as possible.

If you do not receive our confirmation e-mail regarding your registration, your participation cannot be guaranteed.

Cost

€270 + VAT.  Net investment after subsidy from the HRDA of €102: €219,30 (including VAT) for all eligible participants*

*Last Date for 10% Early Bird Discount: 11/05/2023

Discounts available

• For more than two (3+) participants from the same company a 10% discount is available on the total cost, before the VAT and HRDA subsidy. This discount only applies for participants who enroll in the same seminar, on the same day. This discount can only be combined with the early bird discount and the HRDA subsidy, when applicable.
• For individuals/legal entities who/which register in more than two (3+) seminars during the same semester (January-June & July-December), a 10% discount is available on the total cost, before the VAT and HRDA subsidy. This discount only applies for individuals/legal entities who/which enroll in more than two (3+) seminars during the same semester, on the same day. This discount can only be combined with the early bird discount and the HRDA subsidy, when applicable.
• There is a 10% discount for alumni members. This discount should be applied before the VAT and HRDA subsidy and can only be combined with the early bird discount and the HRDA subsidy, when applicable. For more information on our alumni scheme, click here.
• There is a 10% early bird discount on selected seminars for participants who enroll in a training course until a specific date which is stated above. This discount should be applied before the VAT and HRDA subsidy and can only be combined with the HRDA subsidy, when applicable.
• HRDA subsidy for all HRDA approved seminars. 

Contact

For any queries, please contact us on +357 22 209 237 or at academy@kpmg.com.cy.

CPD

This seminar may contribute to Continuing Professional Development requirements. At the end of the seminar participants will be given a certificate of attendance confirming the total number of training hours (6 CPD).

Costas Markides 
Board Member, International Tax, KPMG in Cyprus

Costas is a Southern Illinois University graduate, holding a Masters degree in Accountancy with a special concentration in International Taxation. He has been the recipient of two full academic scholarships and has graduated first in his class, at the College of Business Administration with a perfect score. Costas is a Certified Public Accountant and a member of the American Institute of Certified Public Accountants (AICPA). He is also a member of the Cyprus Institute of Certified Public Accountants (ICPAC) and a member of the Institute’s Tax Policy and Planning committee. Costas is also serving as an advisor to the Ministry of Finance on issues relating to double tax treaty negotiations and policy.

Costas is a specialist on International Taxation with more than 20 years of experience in the field. He is a regular speaker at various conferences that are being organised in Cyprus and abroad. He is the author of numerous Tax related articles that have been published in Cyprus and the US.

Volodymyr Serdechniuk
Senior Manager, Transfer Pricing, KPMG in Cyprus

Volodymyr is a graduate of the Taras Shevchenko National University of Kyiv, holding a master’s degree in Mathematics.

Volodymyr has more than eight years of experience of transfer pricing practice in four different countries. During his tenure, that started in 2014, he was in charge of more than 100 transfer pricing engagements serving local and multinational enterprises from all major industries on various topics, from fulfilling compliance obligations to establishing efficient intragroup pricing policies.

Volodymyr advises clients from more than ten different countries. One of his major projects includes advising a major multinational company in relation to concluding a bilateral advance pricing agreement.

Michalis Fiakkou
Manager, International Tax, KPMG in Cyprus

Michalis is a Manager in the International Tax department of KPMG in Cyprus, possessing 10 years of professional experience. He joined the firm in 2018 and  specialises in Transfer Pricing and DAC6. He is a member of the Association of Chartered Certified Accountants (ACCA) and the Institute of Certified Public Accountants of Cyprus (ICPAC).

Michalis is actively involved in advising international and local clients on their transfer pricing obligations and assisting them in the preparation of the required transfer pricing documentation. Additionally, he is highly involved in assisting clients in understanding how DAC6 rules affect their day-to-day operations and fulfilling their DAC6 reporting obligations in Cyprus.