Fundamental of International Taxation and Treaty Interpretation (Batch 8)

When:
Batch 19 (16 February – 23 March 2019)

Activity Time (per batch):
Every Saturday from 09.30 a.m. to 03.30 p.m

Session (per batch):
5 sessions (4x materials and 1x exam)

Where:
DDTC Academy
Menara DDTC (1^st Floor)
Jl. Raya Boulevard Barat Blok XC 5-6 B
Kelapa Gading Barat, Kelapa Gading
Jakarta Utara, DKI Jakarta,14240 – Indonesia

Investment:
IDR 8.000.000

Background:
Today, governments in a large number of countries, including the Indonesian government, are aware of the risks associated with price manipulation conducted by international groups in their cross-border transactions. Transfer pricing regulations exist to address pricing issues and the allocation of profits in multinational groups based on the distribution of risks, assets and functions across multinational groups.

To enhance the understanding of transfer pricing principles and analysis, as well as its recent developments, hereby, DDTC Academy provides an intensive course program. The curriculum is designed based on reputable international courses and university programs attended by DDTC Academy lecturers. Therefore, this program is also suitable for those who wish to obtain international certification on taxation or related post-graduates program.

The focus of this course is a comprehensive discussion on the Indonesia tax regulation concerning Transfer Pricing, OECD Transfer Pricing Guidelines 2017, UN Manual on Transfer Pricing 2017, the developments related to the OECD/G20 Base Erosion and Profit Shifting (BEPS) project and new model for Transfer Pricing Documentation.

Moreover, this course is equipped with comprehensive discussion and explanation of the implementation of the Minister of Finance of the Republic of Indonesia Regulation (PMK-213/PMK.03/2016) on Types of Documents and/or Additional Information to be Stored by Taxpayers Conducting Transactions with Parties with Special Relationship and the Procedures. PMK 213/PMK.03/2016 regulates 3 (three) types of documentation to be conducted by Taxpayers, namely: master file documentation, local file documentation, and country-by-country report). PMK-213/PMK.03/2016 is a legal framework providing more details on the preparation of transfer pricing documentation as delegated by the Government Regulation No. PP 74 of 2011 article 10 paragraph (2).

In addition, this course will also discuss the country-by-country report (CbCR) as stipulated in the Regulation of the Director General of Taxation No. 29/PJ/2017 on Reporting Management Procedures per Country. This discussion covers update on CbC reporting regulation:

• Parent entity definition, notification obligation, timeline for CbCR,
• Handbook on Effective Tax Risk Assessment; Tax Risk Indicators that may be detected using CbCR,
• Ex-ante approach and contemporaneous documentation in transfer pricing analysis: arm’s length behaviour,
• Next step and implementation: critical point and the issues.

The objectives of this course are:

• Participants understand the importance of international transfer pricing to multinational enterprise groups and tax administrations,
• Participants understand the importance of transfer pricing documentation in a company’s risk management strategy,
• Participants have an overview of the OECD Transfer Pricing Guidelines and the new guidance introduced as part of the OECD BEPS Project,
• Participants understand the arm’s length principle, the concept of comparability and the transfer pricing methods in the OECD Transfer Pricing Guidelines,
• Participants have a better understanding on Indonesia transfer pricing rules and practices including the practice of making a transfer pricing documentation in accordance with PMK-213/PMK.03/2016),
• The course comprises several examples and a comprehensive case study to enable participants to gain confidence in applying the skills acquired.

Topics Covered:

• Introduction, Basic Framework Legal Basis and Trends in Transfer Pricing,
• Arm’s Length Principle, Functional Analysis and Value Chain Analysis,
• Transfer Pricing Methods,
• Comparability and Measurement of Arm’s Length,
• Specific Transactions,
• Compliance Issues and Dispute Resolution,
• Comprehensive Discussion in the Practice of Making a Transfer Pricing Documentation in accordance with the Minister of Finance of the Republic of Indonesia Regulation (PMK-213/PMK.03/2016).

Who should attend?
The course is suitable for company staff, student, CFOs, tax directors, tax managers, accountants working in companies performing financing activities across all industries, treasury managers, chartered accountants, financial controllers and analysts, internal and external auditors, tax experts and lawyers.

Our Excellence:

• DDTC is a research and knowledge based institution.
• DDTC Academy is acknowledge as a course provider for Advanced Diploma in International Taxation (ADIT) certification by Chartered Institute of Taxation (CIOT), UK.
• DDTC was given an award by International Tax Review’s World Tax and World Transfer Pricing 2018 acknowledging our Managing Partner, Darussalam as a leading adviser and DDTC as a recommended firm in Transfer Pricing.
• Senior Partner DDTC, Mr Danny Septriadi, was selected as one of the World’s Leading Transfer Pricing Advisers 2017 by Expert Guides (one of the most trusted resources for international buyers of legal services).
• DDTC has published a number of bestselling transfer pricing books.
• Managing Partner and Senior Partner DDTC have been acknowledged as expert contributors for reputable national and international academic journals.
• Highly rated instructors. Our instructors are experienced trainers who consistently receive the highest rating for their presentations, have multidisciplinary educational background and hold world-class international certification, as follows:
  • 9 Master’s Degrees in International Taxation from leading universities abroad;
  • 1 Bachelor’s Degree (LL.B) in Taxation Law (Fiscal Recht from Leiden University, The Netherlands);
  • 4 Advanced Diplomas in International Taxation (ADIT) of the Chartered Institute of Taxation (UK);
  • 1 Diploma in International Taxation of International Tax Center, Leiden University, The Netherlands;
  • 11 Certificate Holders of International Tax Certificate from the Chartered Institute of Taxation (UK);
  • 15 Certificate Holders of Transfer Pricing from the Chartered Institute of Taxation (UK).

• Our topics always keep up with the latest taxation issues which are published via books, InsideTax (a semi-journal magazine), working papers, journals and DDTC News.
• Interactive training and case studies models.
• Up-to-date materials, relevant course contents and supported by a dedicated tax research team.
• To offer high quality training programs, DDTC equips its resources with a library that has more than 2,700 collections pertaining to transfer pricing, international & domestic taxation, and other subjects from reputable publishers and authors.

Our Facilities:

• Menara DDTC, new office building with new atmosphere, the best and most comprehensive professional training facilities (theater classes, cozy room, new concept and modern design, moot court simulation room, free Wi-Fi, modern facilities, etc.).
• Library access of more than 2,700 books and taxation journals.
• Exclusive training kits (goodie bag, notepad, pen).
• Getting “Kartu Peserta Training” that can be used as a discount card to re-attend our next training programs.
• Getting “Certificate of Training”.
• Lunch and coffee break are provided.