THE INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS OF KENYA
(Established under the Accountants Act, Laws of Kenya)
Transfer Pricing Workshop (Mandatory Training) – Recording
Date: 13th – 14th December 2023
Time: 9.00am-3.30pm
Venue: Online
(This is one of the mandatory trainings for Practicing Certificate consideration)
Overview
Transfer pricing refers to the prices of goods and services that are exchanged between companies under common control. For example, if a subsidiary company sells goods or renders services to its holding company or a sister company, the price charged is referred to as the transfer price.
Transfer pricing strategies offer many advantages for a company I.e. helps in reducing duty costs by shipping goods into countries with high tariff rates by using low transfer prices so that the duty base of such transactions is lowered hence reducing income and corporate taxes in high tax countries by overpricing goods that are transferred to countries with lower tax rates helping companies obtain higher profit margins.
Some of the risks involved in transfer pricing are the following: Occurrences of disagreements within the divisions of an organization regarding the policies on transfer pricing, its a complicated and time-consuming methodology, difficulty in establishing prices for intangible items such as services rendered which are not sold externally, Sellers and buyers performing different functions hence assuming different types of risks. For many multinationals with cross-border transactions, taxation that is based on transfer pricing is becoming a significant concern. Transfer pricing refers to the pricing of goods, services and intangibles between related parties located in different countries. The transactions between related parties are to be carried out at an “arm’s length” basis. Prices are meant to efficiently allocate resources in the market whereas the role of transfer prices is to efficiently allocate resources within a company as they move from one related entity to another.
In Kenya, Transfer Pricing rules became effective from 1st July 2006 and borrowed significantly from the Organization for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines. Under Section 18(3) of the Income Tax Act (ITA), transactions between a resident entity and it related non-resident should be at arm’s length. The Rules form the basis for the determination of the arm’s length price in transactions between related parties. They entitle the Commissioner to adjust transaction prices where he is of the view that the related parties did not transact at arm’s length.
The OECD Transfer Pricing Guidelines have changed considerably over the past few years. Consequently, policies are being reviewed and in some cases changes to pricing have to be made. Multinational enterprises must determine now what practical implications they face and how they can best operate within this radically changed regulatory environment.
The symposium intends to enhance the participants’ understanding of transfer pricing by focusing on:
• OECD Transfer pricing guidelines and the Arm’s length principle
• OECD Risk Analysis
• Transfer Pricing Documentation
• Transfer pricing compliance and emerging issues
• Resolving and handling transfer pricing disputes
• The implications of BEPS for Transfer Pricing
Target Audience
This workshop will be useful to all professional Accountants and those aspiring to join the profession
Continuous Professional Development Units (CPD Units):
Members of ICPAK and reciprocating professional bodies will be awarded 10 CPD Units upon successfully attending the session.
Cost:
Charges for the training will be Kes 10,000/= which will cover workshop fees, materials, and e-certificates of attendance.
Online Booking:
We call on Seminar participants to note that booking for is available only online at www.icpak.com/events and will close two hours before the training session. Delegates are reminded to note that online booking for training sessions is mandatory. This is available either online at www.icpak.com/events or on the ICPAK Live – A smart phone-based application that is available from google store.
National Industrial Training Authority (NITA) Reimbursement:
The Institute is registered as a trainer with National Industrial Training Authority. The Institute’s registration number is DIT/TRN/47. Participants who are registered levy contributors should apply to NITA for reimbursement of their fees. Please note that this is applicable for Kenyan citizens only and subject to NITA regulations. Remember that to qualify you should apply to NITA for approval prior to the date of the conference. Further details can be obtained from their website (www.nita.go.ke)