Seminar (Taxation on Intercompany Financing)

When:
Wednesday, 07 August 2019

Activity Time:
09.00 am – 05.00 pm

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 3.000.000 (include VAT)

Background:
Different tax treatments between debt and equity create a distortionary effect on financing decisions. As a result, taxable firms will react by opting for more debt in their capital structure, particularly in the context of cross-border financing.

The idea of cross border excessive debt shall be of greater importance should it occur within multinational enterprises (intra-group). With their common strategy and ability to coordinate under the same effective control, multinational enterprises would have the flexibility to develop any debt scheme and to place debt in a high-tax country. For instance, the use of hybrid financial instruments has gained significance in international finance, while thin capitalization and back to back loan have received attention from G20 countries on their BEPS project. Further, intercompany financing has also received some attention in light of the transfer pricing issues.

Apart from the theory and intentional best practices, the seminar concludes with recent domestic law and how companies should comply with the rules.

Topics Covered:

1. Tax debt bias and business behavior
2. Hybrid financial instrument
3. OECD/G20 BEPS Action 4: interest limitation rule
4. Debt to equity ratio vs. arm’s length capital structure
5. Arm’s length financing behavior and interest rate
6. Comparability analysis for transfer pricing of intercompany loan
7. OECD Discussion Draft on the transfer pricing aspects of financial transaction 2018
8. Tax implication on selected financing model: cash pooling and guarantee fee
9. Managing tax compliance toward DER rule in Indonesia

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:
  • 8 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;
  • 14 Certificate Holders of International Tax Certificate from the Chartered Institute of Taxation (UK);
  • 16 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.