The year has just begun, and the new season of action from the EUCON Legal Group has already sped up! So, on January 24, at the Admiral Hall, within the framework of the seminar “Transfer pricing: theory on the examples”, our experts shared their experience in the field of transfer pricing practice with the participants of the Event – representatives of companies that are subject to the laws in the field of TP.
Larysa Vrublevska, auditor, partner, manager of the transfer pricing practice of the EUCON Legal Group, told the audience about the procedure for inventorying controlled transactions for 2018, particularly on the principles of assigning transactions to controlled, application of a value criterion, on business transactions between a non-resident and his permanent representative office in Ukraine, calculation of volume transactions with the counterparty, the mechanism for calculating the value criterion, calculation of the amount of annual income (accounting for IFRS), peculiarities of the use of Lists No. 480 and No. 1045 of the Cabinet Ministers of Ukraine, recent letter rulings of the State Fiscal Service of Ukraine on the recognition of transactions controlled. The speaker also gave practical examples and analyzed the most common mistakes.
The topic “Economic analysis: the use of the method of comparative uncontrolled price (CUP), sources of information, practical examples of the application of the method” was discussed by Victor Biloblovsky, the tax consultant of the EUCON Legal Group. Thus, the expert presented a report on the nature of the CUP method and its priority, the determination of the comparability of the characteristics of goods for the CUP method, the specifics of the application of the CUP method to the commodities having stock quotes, available sources of information, the practical application of the CUP method to lending transactions, reinforcing the statement by practical examples.
An informative and rich presentation was made by Zhanna Biloblovska, Auditor, Tax Consultant of the EUCON Legal Group on the topic “Economic Analysis: Using Methods Based on Profitability Estimates. Segmentation of Financial Reporting Indicators: Accounting Aspects: Practical Examples.” The speaker told participants about the peculiarities of analysis of the methods of TP, the choice of the financial indicator in the net profit method, the tools for adjusting the indicators of profitability, the algorithm of segmentation of financial reporting indicators, etc. by demonstrating interesting cases as examples.
The report of Yuriy Chebotar, Deputy Chief of Transfer Pricing Practice, a tax advisor of the EUCON Legal Group, was the next one. The expert, in his speech on the topic “Search for comparable transactions and comparable legal entities”, described the elements of the comparability, namely, indicating the most frequently used criteria in practice, the search algorithm for comparable companies, the formation of the primary sample and the search strategy of the comparable individuals in the database, checking companies manually, analysis of the possibility of using their own comparable uncontrollable transactions (or counterparty transactions), information sources, constructing and calculating the price range / profitability and bringing sample examples.
The seminar was completed by Larysa Vrublevska’s speech with a practical step-by-step example of justification of the price level in controlled import transactions. Economic and comparative analysis was presented in detail. Thus, Ms. Vrublevska described concretely about the algorithm of analysis, the mechanism for conducting functional analysis, the criteria which the most appropriate method of transfer pricing was chosen by, the methods of the TP as well and about peculiarities of the calculation of the profitability range, the self-adjusting, the adjustment for the consequences checking.
P.S. Let’s recall that the annual International Forum “Transfer pricing – 2019”, organized by the EUCON Legal Group, will be held in May. This year’s forum will be held for fifth time and will traditionally gather representatives of state authorities, business and leading experts on one platform. So, we invite everyone who has the desire to visit the Event. The registration will be opened odd-come-shortly! Follow our news on the Facebook page and on our site http://www.euconlaw.com/.
