Registration Time: 13:15
Sessions Time: 13:30 - 16:45  including a 15-minute break
Speaker: Ms Trudy Muscat & Dr Timothy Borg Olivier
Venue:   Online Webinar

Participation Fees (The Institute is now accepting payments via Paypal)
MIA Members: €70.00

Non-MIA Members: €140.00

Retired Members: €30.00

Students: €50.00

Session 1: A Hands-On Approach to Transfer Pricing in Malta

BACKGROUND INFORMATION

 This session is intended to provide a deep-dive into the Transfer Pricing Rules introduced locally and the corresponding Guidelines published by the Malta Tax and Customs Authorities, including through a series of practical examples. The session shall also address the relevance of the OECD Transfer Pricing Guidelines with respect to the application of the local Transfer Pricing Rules.

SPECIFIC TOPICS TO BE COVERED DURING THE SESSIOn

• Malta Transfer Pricing Rules and Guidelines
• Relevant parts of the 2022 OECD Transfer Pricing Guidelines
• Practical cases relevant to the Maltese practitioner
• Transfer pricing studies
• Transfer pricing documentation

Session 2: Transfer pricing implication for Profit Attribution to Permanent Establishments

BACKGROUND INFORMATION

This session is intended to provide insights into the scenarios which may give rise to a Maltese permanent establishment, and the rules governing PE profit attributions, including through a series of practical examples. The session shall also address the relevance of the OECD Transfer Pricing Guidelines and the 2010 OECD Report on the Attribution of Profits to Permanent Establishments with respect to the application of the local Transfer Pricing Rules

SPECIFIC TOPICS TO BE COVERED DURING THE SESSIOn

• The local interpretation of OECD Model Tax Convention Article 7 and Article 5

• Malta Transfer Pricing Rules and Guidelines

• 2010 OECD Report on the Attribution of Profits to Permanent Establishments

• Local tax treatment of profits attributed to a permanent establishment

• Practical cases relevant to the Maltese practitioner

Service providers working within groups with international presence.

WHY IS THE SESSION OF RELEVANCE TO OUR MEMBERS?

Following the introduction of Transfer Pricing Rules locally, with effect from 1 January 2024, now that the dust has settled and we are starting to come to terms with the Rules and Guidelines published, this session will delve into some of the practical implications relating to the introduction of transfer pricing rules in Malta.

Speakers' Profiles

Trudy Muscat: A senior manager within Deloitte’s international tax team, Trudy is an experienced international tax lawyer with a demonstrated history of efficiently leading a team to support MNEs with cross-border tax permutations, particularly focused on the entertainment and tech industry. Fifteen years work experience in corporate international tax law, personal holding solutions, tax strategy and policy, transfer pricing and controversy. Tax law and transfer pricing lecturer, coordinator and examiner. Specialisation in EU tax policy and developments.

Timothy Borg Olivier is a lawyer by profession and is currently a Senior Manager within the international tax team at Deloitte Malta. Timothy studied law at the University of Malta before furthering his studies at the University of Leiden where he read for and successfully obtained an Advanced Masters in International Tax Law from the International Tax Centre. Following his graduation, Timothy served as a Teaching Assistant within the International Tax Centre. Timothy advises and assists a number of local and international clients in connection with cross border transactions and has particular industry expertise in relation to the iGaming industry.

EVeNT CPE COMPETENCies

6  Core

WEBINARS TERMS AND CONDITIONS

Terms and conditions  apply

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