Fundamentals of Transfer Pricing

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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.

Learning objectives


  • Define 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
  • Interpret the arm’s length principle, the concept of comparability and the transfer pricing methods in the OECD transfer Pricing Guidelines
  • Identify the challenges raised by the digital economy and the proposals from (i) the OECD such as the “Unified Approach”, Global Anti-Base Erosion (GloBE) Proposal under Pillar Two and the Globe and the Two Pillar Approach, (ii) the European Union, and (iii) unilateral measures of countries to tax the digital economy
  • Apply the arm's length principle in practice, based on the guidance provided in the OECD Transfer Pricing Guidelines
  • Define the purpose and content of Transfer Pricing documentation, including having an understanding of international guidance on this subject
  • Differentiate mechanisms for avoidance and resolution of transfer pricing disputes, including advance pricing agreements, the mutual agreement procedure and arbitration (under the European Arbitration Convention and under Tax Treaties)

Delivery method

QAS Self study

Field of study


Course review

This course was last reviewed in April 2021


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 use the OECD Transfer Pricing Methodologies. In addition, taxation of the digital economy and transfer pricing adjustments are considered, along with transfer pricing documentation and dispute resolution and avoidance mechanisms.

The course is highly recommended for participants with no or limited knowledge and experience with international transfer pricing, however it is also suitable for those that 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.

Study time

  • Audio lessons:  6 hours
  • Self study:  21 hours
  • Further reading (optional)

Access to the course is granted for a period of 12 months, from the date of ordering. 

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) - 27 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.