Transfer Pricing and Business Restructuring

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The Transfer Pricing and Business Restructuring course provides a practical guide to the transfer pricing aspects of business restructurings for taxpayers as well as tax authorities. This course includes techniques for use in developing or assessing the transfer pricing implications of any changes to the structure and activities of corporations.

Topics Covered

  • Business models and digital transformation
  • Importance of business restructurings – tax perspective
  • Recognition of business restructuring
  • Arm’s length consideration for restructuring
  • Conversion issues and post restructuring issues
  • Selected Issues in global value chain analyses
  • Business restructurings and indirect taxes

Learning Objectives

Skills practiced and developed during the course include:

  • Identify the drivers for business model transformation and the role of data
  • Define the common types of business restructurings and the related policy framework
  • Identify the important considerations in the accurate delineation and non-recognition of business restructurings
  • Apply the various concepts such as options realistically available and commercial rational behavior in relation to business restructurings
  • Apply the four-step approach for determining an arm’s length compensation for the transfer of “value” in a restructuring
  • Identify the tax accounting considerations and reporting issues related to the business restructurings
  • Assess the impact of business restructuring from a VAT and customs perspective

Delivery Method and Core Study Time

Online (QAS self-study)

Transfer Pricing and Business Restructuring consists of 7 modules with video lessons of approximately 1 hour each, recommended reading materials and assignments to help apply knowledge in practice.  There will be assessments to test your overall understanding.

Field of Study


Who Should Participate

The course is open for all; however, it would be highly beneficial for:

  • Tax lawyers from law/and or accounting firms
  • Tax/TP managers of law/accounting firms
  • Tax/TP managers/directors of MNEs
  • Finance manager/controllers/treasury managers of MNEs
  • Tax inspectors from tax administrations


No advance preparation is necessary. All required study material is provided within the online training.

Components of Training and Study time

The course is divided into 7 modules, that further consist of several submodules. Each module has following components:

  • Videos: 3-5 videos per module
  • Case-studies: 1-2 per module
  • Assignments and Assessments:  2 assessments for each specialised field
  • Reading material: for each module

The course must be completed within 2 months and can be followed and completed by dedicating a minimum of 5 hours of study per week. Study materials included in the course will be accessible for 2 months.

Continuing Professional Education (CPE)

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.

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. Issues regarding registered sponsors may be submitted to the National. Registry of CPE Sponsors through its website: Recommended NASBA CPE credits for this course is: 13

Please consult the FAQ for more information. Regarding administrative policies such as complaint, cancellation and refund, please refer to our Terms and Conditions or contact


Course Review : This course was last reviewed in July 2023