Cambodia has come a long way since Prakas 986 which introduced formal transfer pricing (TP) regulations in 2017. Preparing TP documentation is now part of the compliance of nearly every large taxpayer, and tax audits by the authorities have increasingly scrutinized all transactions with related parties. But how effective is your planning, how strong your defense? As tax audits accumulate year after year, how will these issues finally get resolved? What is the strongest TP defense possible?
In this highly practical workshop, TP and tax experts of VDB Loi share their real case experience with you from the frontlines of TP and tax disputes.
Highlights
- Companies with a loss or a low profit: how to defend yourself and find comparable companies with comparable profit margins.
- How to save costs on your TP compliance reports.
- Selling goods at lower prices to group entities without TP problems? This is how to plan for it.
- What financial information you need for the GDT to accept low- or interest free loans.
- Management fees paid to the head office: how to justify them in TP reports?
- Renting property from group companies: GDT audit and possible defenses for a low rent.
- What are the acceptable reasons for lower sales prices to related parties?
- “Fake” profit margins imposed by the GDT: how to prepare a strong defense.
- 5 secret tips to win a TP or tax audit.
Program
| TIME | PROGRAM |
|---|---|
| 20 mins | Topic 1: Selling goods or products to group companies - How can you justify price differences in accordance with TP rules? - Which requirements of Prakas 986 apply and how to manage it? - How can a TP Report help your defense? |
| 20 mins | Topic 2: Companies with losses or low profits - How will the GDT often challenge systematically low profitability? - Audits that go on and on and on: How can you clear a never-ending tax audit? - Benchmarking on TNMM for different profit level indicators |
| 20 mins | Topic 3: Management and service fees paid to group entities - What is the best defense: benchmark the transaction or the overall profit margin? - Common ways how the GDT scrutinizes management fees - 5 “secret” ways how to build a solid defense on service fees |
| 20 mins | Topic 4: Group loans and rental agreements - Withholding tax claims by the GDT - Useful tips to save costs on TP Reports! - What are the documents you need for an acceptable cheap loan or land/building rental? |
| Questions and Answers |
Speakers
Mr. Edwin Vanderbruggen
Senior Partner
Mr. Laysym Sim
Partner
Mr. Sodeth Heng
Partner
Mr. Bunhuy Lee
Senior Tax Manager
Ms. Chanbormey Chrea
Tax Manager (TP)
Event Schedule
| Date | Time | Meeting |
|---|---|---|
| 8 June 2023 | 9.00AM – 10:30AM | Physical meeting @ VDB Loi Office |
| 9 June 2023 | 9.00AM – 10:30AM | Physical meeting @ VDB Loi Office |
| 2.00PM – 3.30PM | Online webinar | |
| 30 June 2023 | 9.00AM – 10:30AM | Physical meeting @ VDB Loi Office |
| 7 July 2023 | 9.00AM – 10:30AM | Physical meeting @ VDB Loi Office |
