Transfer Pricing Aspects of Corporate International Tax Structuring

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

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

Taxes

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 

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.

Prerequisites

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.

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 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. 

Continuing Professional Education (CPE)

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 

FAQ

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.

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