OECD Transfer Pricing Guidelines and Areas of Controversy

This webinar discusses the current trends in transfer pricing controversies associated with the 2022 OECD Guidelines. Follow this webinar if you are interested to find out more about the following:
  • What are some of the post-BEPS changes captured by the 2022 OECD Guidelines?
  • Which aspects are the most contentious?
  •  Do you have the strategies to deal with these contentious areas in case of disputes?

Topics Covered

Block 1: Post-BEPS transfer pricing controversy landscape:

  • Comparables and methodology
  • Hidden transaction
  • Routine plus returns
  • Profit sharing and intangible related returns

Block 2: OECD Guidelines and the causes for transfer pricing controversies:

  • The art of comparable searches and its imperfections
  • Different types of remuneration in OECD Guidelines
  • One-sided methodology vs two-sided methodology

Block 3: Transfer pricing controversies: Common causes and approaches to resolve disputes

  • Understanding causes of transfer pricing controversies and matches with common disputes
  • Approaches to resolve transfer pricing disputes

Learning Objectives

After this course, the participants will be able to: this webinar you will be able to:

  • List the various types of transfer pricing controversies;
  • Associate different types of controversies with various aspects of the OECD Guidelines;
  • Identify the tensions and trade-offs in transfer pricing controversies, as well as options for resolving these disputes; and
  • Assess the advantages and disadvantages of various approaches that may be taken to resolve transfer pricing controversies.


  • Nishana Gosai, Group Tax Executive, Adcorp
  • Shee Boon Law, Consultant, International Tax and Transfer Pricing, IBFD
  • Yvette Nakibuule, Associate, Middle East and North Africa, IBFD (Facilitator)

Field of study


Who should participate

This webinar would benefit tax professionals working in multinational groups, tax and legal advisory firms and governments. More specifically:

  • In-house transfer pricing professionals and advisors in professional services firms looking to understand the stress points in the OECD Guidelines and how transfer pricing controversies could be addressed;
  • Legal professionals assessing the risk of transfer pricing controversy associated with tax structures; and
  • Government officials reviewing and auditing the application of the OECD Guidelines to intra-group transactions of multinational groups.

Course level and prerequisites

This is an intermediate level webinar. Participants in this webinar are expected to have at least three to five years of experience in transfer pricing and be familiar with the key concepts of the OECD Guidelines.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of the OECD Guidelines. 

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 24 Nov 2022

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE 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: www.nasbaregistry.org. NASBA CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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