UnscheduledPrinciples of Transfer Pricing
- Principles of Transfer Pricing
Overview and learning objectivesOn 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. 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 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.
In order to deal with all developments in the field of transfer pricing properly, it is essential to fully understand the transfer pricing principles and methodologies and their practical application. This five-day intermediate-level course introduces participants to such principles and methodologies and then covers their application to specific categories of intra-group dealings. The theoretical sessions are complemented by case studies.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 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 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.
In 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 email@example.com.
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 Education
Recommended NASBA CPE points for this course: 32 (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 details
The 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
- 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