Offline training∗ “How to win a dispute over transfer pricing: practical advices and judicial practice”
Date: December 2nd
Price: 4900 UAH with VAT
Duration: 10:00 – 14:30
Place: Kyiv, KPMG office
Detailed information – https://cutt.ly/tTybDd7
Registration – https://cutt.ly/tTybDd7
Use promo code EBAtco10 and get a 10% discount on participation in the training.
— statistics of inspections and disputes on transfer pricing as of 2021;
— recognition of transactions as controlled: features of judicial practice;
— “technical” disputes over transfer pricing: timeliness of reporting, completeness of declaration, application of penalties;
— features of inspections on shopping centers: quarantine moratorium, grounds for conducting, protection algorithm;
— strategy of protection in disputes “in essence”: tendencies of practice and features of proving in court;
— change by the tax authority of the method of transfer pricing: how to protect your position;
— application of the method of comparative uncontrolled price as a priority;
— how to justify the selection of comparable companies when using the method of “net profit”;
— current legal positions of the Supreme Court in transfer pricing disputes;
— the practice of applying by the tax authority 30% adjustment of the financial result for the amount of the value of goods (works, services) purchased from non-residents from low-tax jurisdictions.
At the training you will learn:
— what the tax authorities pay attention to during inspections of the shopping centers;
— what are the features of gathering evidence in transfer pricing disputes;
— what conclusions from the most resonant tax disputes with the shopping center of the business should be taken into account today;
— how to build an effective defense strategy to win a dispute with the shopping center in court.
Who will be interested in the training?
— chief accountants;
— heads of legal departments;
— owners of companies in the financial and real sectors of the economy.
What you will get:
— share the practical secrets of protection in disputes over transfer pricing;
— after the training you will receive a certificate and a presentation with a unique analysis of resonant and precedent tax disputes with the shopping center;
— the most active participants will receive individual advice from the head of the practice for resolving tax disputes.
Nataliia Musiienko, Lawyer, Head of Tax Dispute Resolution Practice KPMG Law Ukraine
She has a successful experience of representation during tax audits and tax disputes of clients of various business branches: pharmaceutical, agribusiness, media, telecommunications, technology, retail, airlines, manufacturers of industrial equipment, banks and financial institutions.
Natalia accompanies disputes over transfer pricing, disputes with “fictitious” transactions, disputes over the correctness of the application of NP(S)BU and IFRS. Natalia is a member of the Ukrainian Bar Association, the American Chamber of Commerce and the European Business Association.
Iryna Khyliak, Lawyer, Tax Dispute Resolution Practice Manager, KPMG Law Ukraine
Irina’s professional experience includes protecting the interests of clients from various business sectors in disputes over the unreality of business transactions, the application of preferential rates when paying interest, dividends and royalties in favor of nonresidents, registration of tax invoices, the operation of electronic VAT administration.
Sofiia Baranovska, Senior Lawyer for Tax Dispute Resolution, KPMG Law Ukraine
Sofia works with disputes over non-admission to tax audits, the reality of transactions, transfer pricing. Sofia’s professional experience also includes support for tax audits, preparation of responses to requests from tax authorities, appeals against individual tax consultations.
* training is carried out taking into account all quarantine restrictions, details will be sent to participants in person after payment of participation. The organizers do not conduct trainings at the “red” level of epidemic danger and reserve the right to change the date and time of the event, as well as to postpone / cancel them in case of change in the epidemiological situation in Ukraine.