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OnlineITA109 Fundamentals of Transfer Pricing

Transfer pricing is one of the most important tax issues faced in the international arena of enterprises and tax administrations. This course will examine the legal framework for transfer pricing and the role of the OECD Transfer Pricing Guidelines.
 
 
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Type:
Online Tax Courses
Language:
English
Level:
Introductory
Price:
EUR 499 / USD 674 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
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Type:
Online Course Lessons
Language:
English
Level:
Introductory
Price:
EUR 65 / USD 85 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients
 
Ordering multiple courses: to order more than one online course, please view our instructions.
 

 

ITA109 Fundamentals of Transfer Pricing
Learning objectives
 
  • Appreciate the importance of international transfer pricing to multinational enterprise groups and tax administrations
  • Analyse a country's legal framework for transfer pricing, taking into account international practice and guidance (including the OECD Transfer Pricing Guidelines) and the role of tax treaties
  • Understand the arm's length principle, the concept of comparability and the transfer pricing methods in the OECD Transfer Pricing Guidelines
  • Apply the arm's length principle in practice, based on the guidance provided in the OECD Transfer Pricing Guidelines
  • Understand the purpose and content of transfer pricing documentation, and gain better insight in the international guidance on this subject
  • Appreciate mechanisms for avoidance and resolution of transfer pricing disputes, including advance pricing agreements, as well as the mutual agreement procedure and arbitration (under the European Arbitration Convention and under tax treaties)
Level
Introductory (Basic)
 

Delivery method

QAS Self study
 
Field of study
Taxes
 
Course review
This course was last reviewed in 2015
 
Prerequisites
This course covers, in detail, the fundamentals of international transfer pricing, as it relates to direct, or income, taxation. Focusing on the OECD Transfer Pricing Guidelines, the course addresses the importance of transfer pricing, the legal framework (in particular the role of tax treaties) and the practical application of the arm's length principle by way of comparability analysis and the use of the OECD transfer pricing methodologies. In addition, transfer pricing adjustments are considered, along with transfer pricing documentation and dispute resolution and avoidance mechanisms.
 
The course is highly recommended for participants who have no or limited knowledge of and experience with international transfer pricing. However, it is also suitable for those who have previous experience with transfer pricing and wish to refresh or consolidate their understanding of the topic.
 
While this course is suitable for practising professionals, it is also very useful as additional study material in preparing for the CIOT examination - Advanced Diploma in International Taxation (ADIT – Paper 3 - Transfer Pricing Option). Further information about this qualification can be found at the ADIT website.
 
No advance preparation is needed for this course.
 
Study time
 
  • Audio lessons:  4 hours
  • Self study:  13.5 hours
  • Further reading (optional)
  • Access to the course is granted for a period of 8 weeks
Continuing Professional Education (CPE)
The recommended CPE points for this course are as follows:
 
  • NASBA (The National Association of State Board of Accountancy, US) - 15 points
  • CIOT (The UK Chartered Institute of Taxation) - 17.5 points
  • NBA (Nederlandse beroepsorganisatie van accountants) - 17 points
The International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website.
 
In addition, IBFD International Online Tax Courses in many cases qualify for CPE credits pursuant to the rules of a number of professional associations other than those listed above. Participants are encouraged to check with their professional and/or national associations to determine eligibility in this respect.
 
Read more information on CPE points and accreditation for International Tax Courses.
 

For more information regarding administrative policies such as complaint and refund, please contact International Tax Training via email. Please note that once access to an online course has been granted, a refund will no longer be possible.

Order this course now by selecting 'Register Online' above.

 

  • Introduction to transfer pricing
  • The legal framework
  • Comparability
  • Transfer pricing methods
  • Applying the arm's length principle
  • Transfer pricing adjustments
  • Transfer pricing dispute avoidance and resolution
  • Transfer pricing documentation

 

As a busy tax professional, you are often faced with particular issues that require immediate action. Online Course Lessons offer concise, practical narratives and illustrations on how to understand and solve such specific tax issues. Online Course Lessons are selected from the IBFD International Online Tax Courses. 

 

Course lessons available, learning objectives and study time

 
Comparability – 40 min.
  • Analyse a country's legal framework for transfer pricing
  • Understand the concept of comparability in the OECD Transfer Pricing Guidelines
Applying the Arm's Length Principle – 35 min.
  • Understand the arm's length principle in the OECD Transfer Pricing Guidelines. 
  • Apply the arm's length principle in practice, based on the guidance provided in the OECD Transfer Pricing Guidelines 
Transfer Pricing Methods – 55 min.
  • Understand the transfer pricing methods in the OECD Transfer Pricing Guidelines 
Transfer Pricing Adjustments – 30 min.
  • Understand the purpose and content of transfer pricing documentation, and gain better insight into the international guidance on this subject. 
Dispute Avoidance and Resolution – 30 min.
  • Appreciate mechanisms for avoidance and resolution of transfer pricing disputes, including advance pricing agreements, as well as the mutual agreement procedure and arbitration (under the European Arbitration Convention and under tax treaties).
Transfer Pricing Documentation – 30 min.
  • Apply a country's legal framework for transfer pricing.

Delivery method

Self-study material, accessible online via the IBFD Tax Research Platform.

 

Prerequisites

The course lessons are suitable for professionals who have previous experience with transfer pricing and wish to expand, refresh or consolidate their understanding of specific aspects of the topic. No advance preparation is needed.
 

Ordering

Order online course lessons now by selecting the 'Course Lessons' tab above. You can add the lessons of your choice to the cart and finalize your purchase with the 'Register Online' button.

Authors:

 
  • Joel Lachlan Cooper is Co-Head International Transfer Pricing Group at DLA Piper, based in London, United Kingdom. He provides clients with a fresh perspective on complex transfer pricing matters...

 

Other Contributors:

 
  •  
    Anuschka Bakker is a principal research associate with IBFD in Amsterdam. Prior to joining IBFD, she worked for Ernst & Young and PricewaterhouseCoopers. She has many years experience in...