UnscheduledPrinciples of Transfer Pricing
- Principles of Transfer Pricing
Overview and learning objectives
On 5 October 2015, the OECD published its reports addressing base erosion and profit shifting (BEPS). This new guidance can be considered a game changer and is expected to alter the transfer pricing outcomes in many situations. This requires a different approach from both tax authorities and multinational enterprises, because a significantly more granular risk and functional analysis should be performed. Companies as well as tax authorities need to have a better understanding of how value is created with respect to for example the development and exploitation of their intangibles. A further point of focus is the way in which companies and tax authorities should deal with the three-tiered OECD approach related to transfer pricing documentation.
This course consists of theoretical sessions which are complemented by case studies and examples. After this, you will understand where to find comparables, understand the different comparability factors, be able to use databases and know which type of filters you need to apply. Also, you will be able to determine which comparability adjustments can be made. In addition, you will understand how to determine an arm’s length price for various intra-group transactions and you will know the different elements of a CbC report, Master File and Local File.
This course serves as good preparation for the CIOT’s ADIT Paper 3.03. 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 40 participants. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks.
Field of study
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 prerequisites
This is an introductory-level course. Whilst prior experience of transfer pricing is desirable, it is not a prerequisite to satisfactorily participate in this course.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 matterContinuing Professional EducationRecommended NASBA CPE points for this course: 20.5 (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 IBFD International Tax 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
- Transfer pricing methods
- Transfer pricing and intangibles
- Global supply chain considerations and business restructuring
- Intra-group services
- Intra-group finance transactions
- Administrative approaches to avoiding and resolving transfer pricing disputes
- Case studies