Transfer Pricing Aspects of Corporate International Tax Structuring

The role of transfer pricing in international tax planning

• Transfer pricing in tax structuring
• Transfer pricing and supply chain structures, including 
  impact of OECD Pillar One developments
• Transfer pricing and IP structures

Transfer pricing methodology in the OECD Transfer Pricing Guidelines

• The 9-step process in the application of the arm’s length principle
• Selection of tested party and transfer pricing methods
• Defining and selecting comparables

Applying the arm’s length principle to intra-group transactions

• Determining transfer pricing policies for different types of
  intra-group transactions
• Implementation of transfer pricing policies
• Transfer pricing documentation

Transfer pricing dispute and avoidance and resolution

• Sources of transfer pricing disputes
• Mechanism for dispute resolutions under tax treaties and 
  other international instrument
• Advanced pricing agreements and dispute avoidance

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

• Carlos Espinosa, DLA Piper, UK
• Christos Theophilou, Taxand, Cyprus
• Claudia Stradiotti, DLA Piper, UK
• Costas Savva, Taxand, Cyprus
• Demis Ioannu, Taxand, Cyprus
• Gaspar Lopes Dias, Taxand, UK
• Melissa Kuster, DLA Piper, UK
• Randall Fox, DLA Piper, UK
• Tatiana Amba, DLA Piper, UK

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 

This course is also beneficial for individuals preparing for CIOT ADIT Module 3.03 – Transfer Pricing option, though it is not specifically designed for the ADIT. More information about this qualification can be found on the CIOT ADIT website.

This 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

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

Mandatory course activities - 6 hours 3 min

All mandatory course activities can be completed within the access period by dedicating approx. 45 minutes of study per week. Please note that study materials included in the course or certificate programme will be accessible for the duration of the access period only. Non-mandatory supplementary material is also provided in this course. 

We recommend you check with your respective accrediting organizations to determine the eligibility of CPE credits for this course.

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:  www.nasbaregistry.org.

Recommended NASBA CPE credits for this course is: 6 

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 info@ibfd.org.

• Delivery format: Online (QAS self-study)
• Field of Study: Taxes
• Course last reviewed

Group Participation

If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.