Transfer pricing within the financial services industry and, in particular, for the investment funds industry raises some of the more complex issues in the transfer pricing arena. In the current economic environment, different players in the financial sectors are dealing with various regulatory constraints, operational changes, and strategies to avoid or reduce risk. All these have an impact on the pricing of the transactions between various entities of the group and could also result in potential tax efficiencies. Tax authorities around the globe are increasingly concerned that artificial profit-shifting might erode their tax bases, and consequently as the recession bites multinationals face a high and growing level of risk of challenges due to the “fiscal gap”. Although the course will not focus specifically on the Luxembourg dimension – the issues covered have relevance wherever there is an involvement with a tax system with a tough transfer pricing regime.

The objective of this course is to gain knowledge of transfer pricing aspects related to the fund management industry. 

Upon completion of the course participants will be able to:

• understand the impact of globally integrated activities on their intercompany transactions
• raise relevant questions related to current and new intra-group transaction flows
• identify the main issues that could have an impact on the transfer pricing risks and exposures of their operations as well as the possible solutions and tax efficiencies.

• Basics of transfer pricing in the financial services sector
• OECD guidance for financial services sector (the Report on the Attribution of Profits to Permanent Establishment)
    - Banking and Capital Markets
    - Investment Management
• Management services
• Case study – profit sharing within the multi-national fund management group
• Business restructuring & Transfer pricing in challenging times
• Managing changes to a transfer pricing policy
• VAT impact of cross-border provision of intra-group fund management services – the new package for 2010

• Fund Managers based in Luxembourg or other EU countries
• Executives responsible for the tax line in the profit and loss account
• Accountants and Internal Auditors in the fund management industry

This training is coordinated by David Roach, a senior tax partner at PwC Luxembourg with fifteen years experience in the transfer pricing field.

English

An half-day

The premises of PwC ACADEMY located 400, route d’Esch, Z.I. Cloche d’Or, Luxembourg-Gasperich.

An invoice will be sent to you at the end of the training.

For organisational purpose or in case of absolute necessity, we reserve the right to delay or cancel training events. In such cases, participants will be advised at the latest five business days before the event.

Any cancellation should be communicated in writing at the latest five business days before the event. Thereafter, full fees will be invoiced. Substitution of one participant by another is possible and can be done at any time upon written notice.

An attendance certificate will be sent to participants.

The modules described here can be organised in your premises or can be adapted to your specific needs. Do not hesitate to contact us if you are interested by tailored solution.

Registration fees are eligible for State co-financing in accordance with the legislation relating to the support and development of continuing vocational training. PwC ACADEMY is authorised as a provider of continuing vocational training under registration number 94523/C.