The 105th OECD Tax Seminar on Transfer Pricing Dispute Resolution and Avoidance

Date2017. December 4(Monday) ~ 9(Saturday), 6 days
VenueJeju Islands
Attendees– Experts: Experts from OECD and OECD member countries

– Participants: Senior administrators involved in Competent Authority or APA work, as well policymakers with an interest in MAPs, Arbitration and APAs and the use of safe harbours and other dispute prevention measures.

Main Contents

The purpose of this event is to discuss mechanisms to prevent and resolve transfer pricing disputes with a view to efficiently avoid or eliminate double taxation, in the context of the global standard embodied in Action 14 of the BEPS Action Plan, which aims at reducing costs for Transfer Pricing and Tax Administration related to avoidable disputes while ensuring an adequate protection of taxpayers rights. The workshop is designed to address the theoretical and practical issues arising in the resolution and avoidance of transfer pricing disputes. The topics covered include administrative and juridical appeals, corresponding adjustments, Mutual Agreement Procedures (MAPs), arbitration, rulings, safe harbours, and Advance Pricing Arrangements (APAs). The topics are illustrated by case studies and role plays. Participants are strongly encouraged to present their countries’ legislation and practices regarding dispute avoidance and resolution during the event. Time will also be available for a discussion of any difficulties and experiences by participants.
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