Transfer Pricing and Intra-Group Financing

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The Transfer Pricing and Intragroup Financing course includes a comprehensive and detailed analysis of all facets of transfer pricing and intragroup financing. This intermediate-level course is designed to be practical and includes tools, checklists, roadmaps and step by step approaches to help participants address, substantiate and price intragroup financial transactions.

Topics Covered

  • Introduction
  • Loans
  • Credit Ratings
  • Guarantees
  • Cash pooling
  • Implementation of a robust treasury within an MNE (suitable for all participants except tax inspectors from tax administration)

Learning Objectives

Skills practiced and developed during the course include:

  • Identify the typical types of intragroup financing transactions within MNEs
  • Define the policy framework and the importance of robust pricing of intragroup financing transactions for MNEs and tax authorities
  • Identify the building blocks to analyze intragroup loans
  • Apply the step-by-step approach to analyzing credit ratings, intragroup guarantee transactions and cash pooling
  • Apply the practical roadmap for designing, implementing, and sustaining robust intragroup financing structures and TP policies
  • Assess typical approaches, best practices, and real-life examples of how MNEs are incorporating or can potentially incorporate the OECD Guidelines

Delivery Method and Core Study Time

Online (QAS self-study)

Transfer Pricing and Intra Group Financing 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: 9

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