Book & Pay per Delegate

2ND Annual Transfer Pricing –Tax &Regulatory

Aspects

Key Take Aways& Benefits:

10th

March 2015, Hotel Transit (Mumbai)

One Day Workshop for Financial Fraternity to learn measured approach to Domestic & International Transfer Pricing

- V4C Professional Training

Booking per Delegate INR 15,000 Net +

12.36% Service Tax.

Table of 3 Pax would get additional 10 %

discount.

Capitalize on the expert knowledge to gain maximum

value on these vital issues:

� IMMEDIATELY usable knowledge, skills and methods for enhancing

your Transfer Pricing Policy

� UNDERSTAND Regulatory aspects of Transfer Pricing to determine

whether a particular Transaction is , or is not, covered by Transfer

Pricing Regulations

� RECOGNIZE how to effectively meet the compliance burden

imposed by the Transfer Pricing Regulations

� DISCOVER the secrets to setting your Transfer Prices in a way that

achieves Tax Efficiency without running afoul of the Transfer

Pricing Regulations

� IDENTIFY the ways to avoid the most costly mistakes when

establishing and implementing your organization’s Transfer

Pricing Policy

� Evaluate whether the transfer prices already set by your

organization are in compliance with the regulatory requirements

� PREPARE well for Transfer Pricing disputes with the Tax Authorities

and the resulting litigation

� DISCOVER how to save cost on unnecessary litigation in the area of

Transfer Pricing

� LEARN about the current state of Law including latest Cases and

Judicial Precedents

Nilesh Patel (US-CPA) Transfer Pricing Consultant, Author of Domestic Transfer Pricing Book

(Founder and CEO)Taxwize

� Author of a Book on Domestic Transfer Pricing published by

Taxmann

� Ex- Deloitte & Indian Revenue Services(IRS)

� Ex- Additional Commissioner of Income-Tax, IRS

� Guest Speaker at the Indian Chartered Accountants Institute for their

Intensive Course on Transfer Pricing

� Transfer Pricing Trainer for Medium-Sized & LSE Chartered

Accountant Firms in Mumbai

� Consultant to listed BSE 100 Corporate Taxpayers on complex

Transfer Pricing issues

� Developer of a Software-driven Quiz on Practical Aspects of Transfer

Pricing

� Writer of Articles on Transfer Pricing and International Taxation

� He have studied Transfer Pricing and International Tax at

University of California, Los Angeles (UCLA). He’s a CPA (USA)

from California Board of Accountancy, and an alumnus of IIT Powai.

Nilesh Patel is a highly experienced Transfer Pricing, International

Taxation and Direct Tax professional. His experience covers the entire

gamut of Transfer Pricing and Direct Taxes. He has worked as an

Indian Revenue Service (IRS) Officer on the post of Additional

Commissioner of Income Tax; as a Tax Executive in a US CPA Firm; and

as a Senior Manager (Corporate Tax) with Deloitte.

Nilesh combines an Engineering Degree from IIT Mumbai with a

Certified Public Accountant (CPA) qualification from the US. He is a

member of the American Institute of Certified Public Accountant

(AICPA) and the California Board of Accountancy.

He has helped clients achieve success in Transfer Pricing – planning,

setting prices, testing prices, benchmarking, compliance, study

reports, and litigation, with success with more than 30 Organizations

in 12+ industries.

On the Training side, Nilesh has designed and delivered 11 Transfer

Pricing and Corporate Tax Training Programs to Mid-Sized CA Firms in

Mumbai. His executive training experience includes analysis of

practical issues for Senior Chartered Accountants and Tax

Consultants.

On the Consulting side,Nilesh has led Transfer Pricing and Tax

planning for more than 20 companies and orchestrated change in

Transfer Pricing policy of those companies, including several listed

companies. Nilesh has won more than 15 cases for companies in

Transfer Pricing litigation, appeals and dispute resolution.

Pre Course Questionnaires:

To ensure that you gain maximum benefit from this training, a

detailed questionnaire will be sent to you to establish exactly

where you’re training needs lie. The completed forms will be

analyzed by the course trainers. As a result, we ensure the

course is delivered at an appropriate level and that relevant

issues will be addressed. The comprehensive course material

will enable you to digest the subject matter in your own time.

“Transfer pricing is the leading edge of

what is wrong with Domestic &

international tax”

- Lee Sheppard (Tax Analyst)

Renowned Course Trainer

Day 1 - Sessions

Registrations at -8.30 am | Course Begins – 9.00 am | 10.30 –Refreshment Break

11.00 am –Course commences | 1.00 Pm – Networking Luncheon

2.00 pm- Course recommences | 4.00pm – 4.15pm Afternoon Refreshments

5.40 Pm – Course Concludes

Nilesh Patel – CPA (USA), IRS (Former) Taxwize

SESSION 1: WHAT IS TRANSFER PRICING AND WHEN DO TRANSFER PRICING REGULATIONS APPLY?

• The program begins right off with a case study to illustrate and

examine when is Transfer Pricing triggered? And what is the Arm’s

Length Principle?

• Concept of Associated Enterprises

• International Transactions covered by Transfer Pricing Regulations

• Domestic Transfer Pricing – change in law from FY 2012-13,

additional transactions covered by Transfer Pricing Regulations

• Case studies on the above topics

SESSION 2: WHAT TO DO WHEN TRANSFER PRICING REGULATIONS APPLY?

• The prices of transactions between Associated Enterprises have to

be at Arm’s Length - How to determine the Arm’s Length Price?

• Documentation – what to maintain, when to maintain, how to

maintain?

• Transfer Pricing Audit – when and how to file the Audit Report?

• Penalties

SESSION 3: ADVANCED TRANSFER PRICING METHODS

• Six prescribed Transfer Pricing Methods to compute the Arm’s

Length Price

• Practical examples on application of the six methods

• How to select the Most Appropriate Method?

• Benchmarking of intra-group services, transfer of goods, royalty,

and interest payments

SESSION 4: HOW TO CARRY OUT ECONOMIC ANALYSIS

UNDER TNMM (THE MOST POPULAR METHOD)?

• Nine Step process recommended by OECD

• Functions, Assets and Risks (FAR) Analysis

• Selecting the Tested Party

• Searching for comparables

• Relevant filters to select the final set comparables

• Selection of an appropriate Profit Level Indicator (PLI)

• Computation of PLI

• How to make the right economic adjustments to the PLI?

SESSION 5: TRANSFER PRICING ASSESSMENT TRENDS

AND DISPUTE RESOLUTION APPROACHES

• Representing your case before the Transfer Pricing Officer

• How to defend your transfer prices before the Tax

Authorities?

• Preparing for Transfer Pricing assessments, disputes and

litigation

• The approach and thought process of the Tax Department

• Advance Pricing Agreements

• Safe Harbour Rules

• Mutual Agreement Procedure

Why You Should Attend

This one day program is highly interactive, hands-on and based on the

latest knowledge and real world success examples of Transfer Pricing

compliance, planning and litigation. Participants will learn and experience

the program’s multiple subject modules through business simulations;

presentation of lessons learned; case studies; open sharing; sharing of real

world experiences; and development of Transfer Pricing strategy.

This leading edge program is designed for Corporate Finance and Tax

leaders seeking to understand the concept of Transfer Pricing in the

context of meeting the regulatory requirements and achieving tax

efficiency. This one day program is essential for organizations seeking to

lay down an effective strategy for Transfer Pricing. Such a strategy can

achieve tax efficiency; avoid needless disputes with tax authorities; and

curtail litigation.

Your organization daily undertakes business transactions. Without

identifying the transactions that fall within the domain of Transfer Pricing

Regulations your ability to be in compliance with those Regulations is

drastically diminished. This one day program provides you clear and

immediately applicable knowledge and skills regarding the “What?”,

“Why” “When” and “How” for the critical aspects of Transfer Pricing

compliance and management. Attending this program will equip you to

save tax as well as the cost on unnecessary litigation in the area of

Transfer Pricing.

Who should attend? President, Vice President, Director, Head, Chief, Senior Manager,

Manager and Heads of:

� CFO

� Finance

� Accounting

� Company Law Compliance

� Company Secretary

� Taxation Team

From: Sectors All Sectors of Industry

� Computer Software and Hardware

� Pharma and Healthcare

� Cement/Manufacturing

� FMCG/Electronics

� Oil and Gas

� Government Agencies

� Real Estate/Construction/Infrastructure

� Capital goods

Question & Answers Sessions before End of Day

As the program draws to a close there will be a free-flowing Question and

Answer session. Here attendees can address their specific experience and

questions, with responses coming from the program leader and fellow

delegates.

Learning Logs

The Day will wrap up with attendees taking time to enter their key learning

from the Day’s activities. Such recording of “lessons learned”, possible places

for applying the Day’s ideas and/or new questions for further exploration - all

these, it is proven; enhance learning and the program’s benefits.

Few Testimonials from 1st Annual Transfer Pricing

“Transfer Pricing, both International and Domestic, is the one of the prime concerns of Corporate Tax and Finance Managers and its importance keeps

growing with each passing year. Sound knowledge of Transfer Pricing concepts, rules and processes is now a must for everybody wishing to work in the

fields of Corporate Finance and Tax, either in Industry or in Practice. Mr. Nilesh Patel is an ideal Professional from whom one can learn all practical

aspects of Transfer Pricing.”-Vineet Agrawal, Senior Vice President & Group Head (Taxation), JSW Group

“As a thorough Transfer Pricing Professional, Nilesh Patel represents our Business Group i.e. Glenmark Group, before Transfer Pricing Officer as well as

before Transfer Pricing Appellate Authorities. His approach is very systematic and professional. His written and verbal submissions before Transfer

Pricing Authorities have helped us in getting dispute-free Assessment Orders. I highly recommend this very useful Course on Transfer Pricing to all

aspiring Professionals.” -Sunil Sultania, General Manager Finance, Glenmark Pharmaceuticals Limited.

"Nilesh Patel is a thorough Transfer Pricing and Corporate Tax Professional. He will leave no stone unturned to ensure that the participants are

empowered to work confidently on real Transfer Pricing Assignments. All professionals associated with Transfer Pricing and all professionals thinking of

associating with Transfer Pricing, must avail of this opportunity.

It is no secret that Transfer Pricing has already become one of the most important subjects in Taxation and it is further growing in scope and potential as

a rewarding area of practice and career.“ - Vikram Sankhala,Financial Consultant, V2Solutions

“I have attended two Transfer Pricing training sessions conducted by Nilesh Patel: one was during 'Intensive Course on Transfer Pricing' organized by

ICAI-WIRC and the other was on 'Domestic Transfer Pricing' organized by a well-known CA Firm in Mumbai. The study material provided by him and the

practical knowledge delivered were of high professional standards. He freely shared his deep knowledge of Transfer Pricing and explained various

concepts by drawing real life examples from his rich and varied experience. Speaking from a position of knowledge and experience, Mr. Patel makes sure

that the knowledge gained reflects in the value of your learning effort to your organization.” –Ajay Dave, Chartered Accountant Association,

Mumbai

“I got the opportunity to work under Nilesh Patel on Transfer Pricing and Direct Tax litigation cases in the early days of my career as a Tax Professional.

Working with him was a great learning experience. Nilesh Sir is a natural Teacher and Guide. He not only helped me in understanding the complex tax

laws but also provided insight on practical issues faced by a professional in this field.” - Gautam Gupta , Deloitte

We regularly consult Nilesh Patel while working on our Transfer Pricing Assignments. Under his guidance we have prepared several Transfer Pricing

Study Reports for our clients. He also advises us on making effective representations during hearings before Transfer Pricing Officers. Nilesh Patel acted

as our Trainer earlier when we had newly entered the field of Transfer Pricing.- Nikesh Jain , JMR Group

Complex subject was made easy to understand and was very elaborative” - Harresh Chatbaar ,Head-Business Support, Kongsberg Martime

India

“Faculty was knowledgeable & had good practical experience in the subject which was useful and insightful”.- Vaibhav Karandikar , Director –

Sanofi India

Few Clients Story (Organization’s are confidential) Case 1: Listed Indian Pharma Company transferring a pharma molecule to its Swiss Subsidiary was facing Transfer pricing Issues

The Result: There was no Transfer Pricing Adjustment; the Client was saved from the pain of unnecessary litigation.

Case 2: A US Software Company having a Subsidiary in India was facing isues on appraisal of business operation and was asked to pay

surprise Tax

The Result: The Transfer Price of services rendered by the Indian Software Company to its US Parent Company were

calibrated at Arm's Length Price; and the Client saved Rs. 12 Crores

Case 3: An Indian Company in Logistics Industry expanding its business to the US and Singapore hence significant part of

resources used for expansion was frittered away in resolving Transfer Pricing and Tax issues. That is why Transfer Pricing and Taxes

remain vital areas of concern for Corporate.

The Result: Trouble-free business expansion without Transfer Pricing and Tax problems.

V4C Training Format: • Pre-course questionnaires.

• An in-depth tailored program to address market concerns.

• Comprehensive course documentation.

• Interactive roundtable discussions and breakout sessions.

• Practical exercises International and Local case studies.

• Opportunity to network with an internationally recognized trainer.

Register Now

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V4C Training & Conferences reserves the right to change the venue of, or speakers at the conference should circumstances require.

Transfer Pricing –Tax &Regulatory Aspects 23

rd January 2015, Hotel Westin (A 5star venue in Mumbai)

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Date: 10th March 2015 (Mumbai)

Venue: Hotel Transit (Mumbai)

Ville Parle(E), Behind Sahara Star Hotel

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