UnscheduledPrinciples of Transfer Pricing
- Principles of Transfer Pricing
Overview and learning objectivesIt is often said that transfer pricing is not an exact science. Hence, in order to develop an understanding of transfer pricing principles and methodologies, consideration of their practical application is paramount. This five-day intermediate-level course introduces participants to transfer pricing principles and methodologies and then covers the application of these principles and methodologies to specific categories of intra-group dealings. The theoretical sessions are complemented by case studies that cover the application of the principles and methodologies in practice. The focus of this practically orientated course is on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the issues that can arise in the application of these requirements. On 5 October 2015, the OECD published its reports addressing Base Erosion and Profit Shifting (BEPS). The developments related to the BEPS project will also be covered in this course.This course serves as good preparation for the CIOT's ADIT Paper III – Option F. For more information about the Advanced Diploma in International Taxation you can visit the CIOT’s website.This is an interactive course with a maximum of 32 participants. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks.
Field of studyTaxes
Who should attend?The course is suitable for finance and tax personnel of multinational enterprises, tax accountants, economists and lawyers, in-house tax managers, tax and transfer pricing advisers, and government officials and tax officers.
Course level and prerequisitesThis is an intermediate-level course, containing introductory sessions. Whilst prior experience of transfer pricing is desirable, it is not a prerequisite to satisfactorily participate in this course.
Pre-course preparationIn order to participate in this particular course, no advance preparation is necessary. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks.
Interactive course - "Group Live"
To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 32 participants will be accepted. Early registration is therefore recommended.
We invite you to send us in advance any technical, content-related questions you may have. During the course we will try to address your specific questions, but please note that this will depend on the amount of time available, the relevance of the questions and the order in which the questions are received.
Should you have a question, please send it to firstname.lastname@example.org.
Disclaimer: The information provided during the course has been prepared solely for the instruction of course participants. This information is not intended to constitute advice on any particular matter.
Continuing Professional EducationRecommended NASBA CPE points for this course: 33 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for ITA courses.
Course fee and registration detailsThe course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.
- Introduction to transfer pricing
- Comparability analysis - part I
- Transfer pricing methods
- Comparability analysis - part II
- Intra-group services and cost contribution arrangements
- Transfer pricing and intangibles
- Intra-group finance transactions
- Business restructuring
- Permanent establishments
- Transfer pricing documentation
- Administrative approaches to avoiding and resolving transfer pricing disputes
- Managing the customs-transfer pricing nexus
- Transfer pricing risk management
- Case studies