Mastering Transfer Pricing: Strategies for Global Taxation Event, 14.Apr.2025

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