Transfer Pricing and Intangibles

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The Transfer Pricing and Intangibles course provides an analytical as well as practical insight into the complexities of the transfer pricing and intangibles. This intermediate-level course provides an all-in-one solution for catching up with the latest issues in the analysis of transactions involving intangibles, including case law and expert insights into the topic.

Topics Covered

  • Importance of Intangible Property (IP) in Global Value Chains
  • Identifying intangible property
  • Attribution of intangible related returns
  • Hard-to-value intangibles
  • Regional and Sectoral challenges in analysing intangibles
  • IP planning/ structuring

Learning Objectives

Skills practiced and developed during the course include:

  • Identifying the key drivers of value creation with respect to intangibles
  • Defining the 6-step analytical framework to analyze transactions involving intangibles
  • Defining the different categories of intangibles and how to identify intangibles for transfer pricing purposes
  • Apply the DEMPE concept to determine allocation of intangible-related returns
  • Identifying the practical aspects of dealing with transactions involving intangibles
  • Apply the OECD hard-to-value intangibles guidance and country specific guidance
  • Identifying the regional and sectoral trends in respect of intangibles

Delivery Method and Core Study Time

Online (QAS self-study)

Transfer Pricing and Intangibles consists of 6 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 6 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: 11

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 February 2023