Transfer Pricing Aspects of Corporate International Tax Structuring

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Transfer pricing considerations are critical in corporate tax structuring from the strategic planning perspective as well as from a compliance perspective. This course looks at the key transfer pricing aspects including how transfer pricing rules are applied in the substantive tax structuring of multinational groups' global supply chains and the structuring of intangibles, how transfer pricing arrangements are implemented and how transfer pricing disputes are addressed and resolved in practice.

Topics Covered

  • The role of transfer pricing in international tax planning
  • Transfer pricing methodology in the OECD Transfer Pricing Guidelines
  • Applying the arm’s length principle to intra-group transactions
  • Transfer pricing dispute and avoidance and resolution

Learning Objectives

After completing this course, you will be able to:

  • Associate the transfer pricing considerations with different types of corporate tax structures
  • Apply the transfer pricing principles to supply chain and IP structures
  • Implement  the 9-step process in the OECD Transfer Pricing Guidelines
  • Assess the strengths and weaknesses of OECD transfer pricing methodology
  • Define the transfer pricing policies for different types of intra-group transactions based on the arm's length principle
  • Apply the transfer pricing policies, taking into account operational considerations and interactions with customs and value added taxes
  • Identify different sources of transfer pricing disputes and differentiate the approaches that can be taken by tax authorities
  • Assess the use of a MAP or an APA in resolving and preventing transfer pricing disputes

Delivery method and Core Study Time

Online (QAS self-study)

Consists of four modules of approx. 1 hour video lessons each and case assignments, which help apply knowledge in practice. A final assessment is also included to test your overall understanding.

Field of study


Who should participate

This course will benefit tax professionals working in multinational groups, tax and legal advisory firms and governments, including:

  • In-house tax professionals and advisers responsible for the structuring of corporate group entities and their associated tax affairs 
  • Legal professionals assessing the risk of tax controversy associated with corporate tax structures
  • Government officials reviewing and auditing multinational groups and their corporate tax structuring practices 


his is an intermediate-level course. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and are familiar with the key concepts of international tax law.

Components of Training and Study time

This online course is divided into four modules each consisting of videos of approximately 1 hour per module, case assignments and recommended reading materials.

Access to the online course is granted for a period of 2 months, from the date of ordering.

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

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: 6

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