Fundamentals of Transfer Pricing
The OECD, United Nations, European Union and numerous countries continuously change their guidance in the field of transfer pricing. Supply chains have been and are still under strain and continue to shift from long and lean to agile and resilient. Business models of multinational enterprises (MNEs) are changing and becoming digitized models. In addition, first we had BEPS 1.0, and now we are dealing with BEPS 2.0 and its proposals with respect to Pillar One and Two.
It is, among others, key that both MNEs and tax authorities can: (i) understand and apply the latest guidance in the field of transfer pricing; (ii) perform a granular risk and functional analysis; (iii) attain a good understanding of how value is created; and (iv) understand how you should deal with the three-tiered OECD approach related to transfer pricing documentation.
With so many developments, there is an increased risk of controversy. It is essential to know which dispute resolution mechanisms are in place and, if you were to enter a dispute, how to prepare yourself. Our online course helps you do just that.
- Learn to define the importance of international transfer pricing to MNE groups and tax administrations
- Assess a country’s legal framework for transfer pricing rules, taking into account international practice and guidance (including the OECD Transfer Pricing Guidelines) and the role of tax treaties
- Determine the challenges raised by the digital economy and the Pillar One and Pillar Two proposals
- Identify the different types of operating models of MNEs relevant for transfer pricing and apply a basic value chain analysis
- Identify the comparability factors, apply a functional analysis and distinguish the steps to perform a "comparables" search
- Identify and assess the strengths and weaknesses of each method and define when and how to apply the transfer pricing methods
- Learn to define the purpose and content of transfer pricing documentation, including understanding international guidance on this subject
- Identify the factors affecting transfer pricing risk and the role of transfer pricing risk management
- Distinguish the various dispute resolution mechanisms, including advance pricing agreements, the mutual agreement procedure, and arbitration
- Introduction to transfer pricing
- Understanding the business and value chain
- Comparability analysis
- Transfer pricing methods
- Compliance and documentation
- Transfer pricing risk management and audits
- Transfer pricing dispute resolution and avoiding double taxation
- Regional challenges in transfer pricing
- Tax lawyers from law firms and / or accounting firms
- Tax / transfer pricing staff from law firms and/or accounting firms
- Finance managers / controllers from MNEs
- Tax inspectors from tax administrations, government officials, academics
The transfer pricing training course is recommended for those with no or limited knowledge and experience with international transfer pricing. However, it is also suitable for students or other professionals who have some experience with transfer pricing and wish to refresh or consolidate their understanding of the topic.
Online - QAS Self Study
Mandatory course activities: 13 hours 45 min
All mandatory course activities can be completed within the access period (2 months) by dedicating approx. 1h 45 min hours of study per week.
International Online Tax Courses in many cases qualify for CPE credits, subject to the rules of respective business tax professional associations. 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: www.nasbaregistry.org. Recommended NASBA CPE credits for this course is: 13
To earn a certificate, participants must complete all mandatory components. The syllabus and FAQ on the learning platform provide detailed completion requirements.
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.
