Course Description
This intensive 5-day course provides a comprehensive introduction to transfer pricing fundamentals. Participants will gain in-depth knowledge of key concepts, methodologies, and practical applications of transfer pricing in multinational enterprises. The course covers international guidelines, pricing methods, documentation requirements, and dispute resolution mechanisms.
Learning Objectives
- Understand the principles and importance of transfer pricing in global taxation
- Master various transfer pricing methods and their appropriate applications
- Learn to conduct functional and economic analyses for transfer pricing
- Develop skills in transfer pricing documentation and compliance
- Gain insights into managing transfer pricing audits and disputes
- Explore advanced topics including intangibles and financial transactions
Course Modules
Day 1: Introduction to Transfer Pricing
- Overview of transfer pricing concepts and principles
- OECD Guidelines and international framework
- Arm's length principle and comparability analysis
- Transfer pricing in the context of BEPS
Day 2: Transfer Pricing Methods
- Traditional transaction methods (CUP, Resale Price, Cost Plus)
- Transactional profit methods (TNMM, Profit Split)
- Selection and application of appropriate methods
- Case studies and practical examples
Day 3: Functional and Economic Analysis
- Conducting functional analysis
- Industry and economic analysis techniques
- Value chain analysis in transfer pricing
- Benchmarking studies and databases
Day 4: Documentation and Compliance
- Transfer pricing documentation requirements
- Master File, Local File, and Country-by-Country Reporting
- Risk assessment and management
- Advance Pricing Agreements (APAs)
Day 5: Advanced Topics and Dispute Resolution
- Transfer pricing for intangibles and financial transactions
- Handling transfer pricing audits
- Dispute resolution mechanisms and MAP
- Future trends in transfer pricing
Practical Wins for Participants
- Ability to implement robust transfer pricing policies in their organizations
- Skills to prepare and review transfer pricing documentation
- Strategies to mitigate transfer pricing risks and manage audits
- Insights to optimize transfer pricing in various business scenarios
Credits: 5 credit per day
Course Mode: full-time
Provider: Blackbird Training Centre