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M23096 - The evolution of the Arm’s Length Principle and its implications for Malta (Online)

  • 19 Oct 2023
  • 13:30 - 16:45
  • Online Webinar

Registration


Registration is closed
Registration Time: 13:15
Sessions Time: 13:30- 16:45  including a 15-minute break
Speakers: Dr Trudy Muscat & Mr Jeremy Gatt
Venue: 
  Online Webinar

Participation Fees:
MIA Members: €40.00
Non-MIA Members: €75.00
Retired Members: €20.00
Students: €30.00

*Group bookings for 3 or more participants available.

BACKGROUND INFORMATION

In line with the commitments outlined in Malta's Recovery and Resilience Plan of 2021, formal Transfer Pricing Rules will become effective in Malta from 1 January 2024. What does this mean for related entity transactions and how could international and EU tax developments impact our application of the arm’s length principle?
This session aims to discuss the evolution of the arm’s length principle, providing participants with insight into:
  • The key causes and drivers that have contributed to the arm’s length principle as an internationally accepted standard for determining the appropriate transfer prices for transactions between associated enterprises
  • Its impact on double taxation relief and fair taxation
  • The development of the arm’s length principle in EU legislation
  • Its infiltration in local law and practice
  • Its survival in the context of OECD and EU tax developments.

SPECIFIC TOPICS TO BE COVERED DURING THE SESSION

  • Context of the arm’s length principle
  • The OECD standard, its legal basis and the BEPS project
  • Relief from double taxation and dispute resolution
  • The arm’s length principle in local legislation
  • The arm’s length principle in an EU context, from primary law to Global Minimum Taxation and BEFIT
  • Implications of Pillar 1 on the arm’s length principle.

WHY IS THE SESSION OF RELEVANCE TO OUR MEMBERS?

The arm's length principle lies at the heart of related party transactions, which are increasingly under scrutiny from an international tax arbitrage perspective. Understanding its context, drivers and evolution enables the practitioner to identify red flags in a transfer pricing context and maintain awareness on what is a relatively novel focal point for Malta.

Target Audience

This session is relevant to tax professionals, accountants, lawyers, economists, CFOs and CSPs.

Speakers' Profiles

Trudy Muscat  is a lawyer by profession. She joined Deloitte Malta in 2023, bringing with her 15 years of experience in international corporate taxation, and in particular EU direct tax law. At Deloitte, Trudy manages, coordinates and oversees diverse portfolios, assisting clients with a variety of corporate law and tax advisory projects, including in relation to the setting up of start-ups, complex corporate and operational reorganisations, financing arrangements, rationalisation exercises and functional analyses, health checks, defence files and MAPs. 
Jeremy Gatt  has recently graduated with a Master in Accountancy from the University of Malta after having successfully submitted his thesis on the practical implications of transfer pricing regulation on the international tax landscape in Malta. Jeremy has been working at Deloitte within the International Tax team and has also been involved in Tax Compliance and Grants and Incentives since 2021.


EVENT CPE COMPETENCies

3  Core


WEBINARS TERMS AND CONDITIONS

Terms and conditions  apply


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Please note that all webinars are recorded by the MIA. Such recordings will be retained by the MIA for internal use.
               

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