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14th ATAIC Conference
Monday, July 16, 2018

Special Event

9 - 13 December 2017, Tehran

Recent Events
Czech Prime Minister Proposes Bank Tax
The ruling Czech Social Democratic Party, led by Prime Minister Bohuslav Sobotka, will introduce a special tax on the countrys banks if it wins elections scheduled for later this year.
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UAE Confirms Details For VAT From January 2018
The UAE has provided more details on plans to introduce VAT at a rate of 5 percent across the other Gulf Co-operation Council (GCC) member states on January 1, 2018.
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Tel:  +98 21 3396 7446
       +98 21 3990 3723
Fax: +98 21 3396 7431
Email: m.mollanazar@tax.gov.ir
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Transfer Pricing Fundamental Workshop Agenda

Agenda-Part I

A. Introduction and Background

 1. What is Transfer Pricing?
 2. The Arm’s Length Principle

B. Comparability 

 1. Comparability Factors: Functions, Assets, Risks
 2. Functional and risk analysis  
 3. External comparable data
 4. Comparability adjustments 

Agenda – Part II

A. Transfer Pricing Methods

 1. Traditional Transactional Methods
   a. CUP
   b. Resale Price
   c. Cost Plus 

 2. Profit Based Methods
   a. Transactional Net Margin Method (TNMM)
   b. Profit Split – Residual and Contribution Analysis

 3. Other Intercompany Transfers
   a. Intercompany Services
   b. Intangible Property

B.  Other Transfer Pricing Related Matters
 1. Documentation Requirements
 2. Collateral Consequences
 3. Advance Pricing Agreements

C.  Case Study

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