Value Creation (Intangibles) in Transfer Pricing Training

The subject of intangibles and value creation have become key to transfer pricing, especially,  where multinational enterprises (MNEs) proactively use them to allocate their profits across their  numerous subdivisions.

 As such, most of the transfer pricing audits embarked on by tax  authorities, including the Ghana Revenue Authority (GRA), focus on intensive scrutiny of related  party transactions involving intangibles in an attempt to claim what they perceive as their fair  share of the MNEs’ global tax revenue.

On March 3, 2020, the Court of Justice of the European Union (CJEU) rendered its decisions in three cases, (C-482/18), (C-323/18) and (C-75/18), each of which concerned aspects of Hungarian law. The CJEU decided that the EU freedom of establishment does not preclude Member States from levying a progressive tax on turnover, the actual burden of which is mainly borne by companies controlled from another Member State. The Court also ruled that Hungarian advertisement tax penalty regime disproportionately affected companies located in another EU Member State and was therefore contrary to the EU principle of freedom to provide services.

For more information, please refer to Euro Tax Flash Issue 426.

• Identification of Intangibles (know-how, intellectual property) in related party transactions.

• Determination of ownership of intangibles and the application of the Development, Enhancement, Maintenance, Protection and Exploitation of Intangibles (DEMPE) principles.

• The Arm’s Length Principle in related party transactions involving intangibles.

• Other transfer pricing issues relating to transactions involving intangibles.
  

• Chief Finance Officers
• Finance Directors
• Tax Managers
• Tax Practitioners
• Internal and External Auditors
• Heads of Departments

• Date: 13 April  2021 

• Time: 9:30 am – 12:30pm

• Via: Microsoft Teams

Crystle Obeng

Tel: +233 501 517 807

Email: cobeng@kpmg.com

Ericka Obese-Jecty

Tel: +233 501 364 979

Email: eobese-jecty@kpmg.com

• Corporate Income Tax
• Preparing for Transfer Pricing Audits
• Employment Tax
• Taxation within Ghana’s  Energy Sector
• New Developments in  Ghana’s Tax System