Fundamentals of Transfer Pricing
This course highlights the importance of transfer pricing, the legal framework, and the practical application of the arm’s length principle through value chain analysis, comparability analysis, and the use of OECD transfer pricing methods. It also covers taxation in the digital economy and transfer pricing adjustments, along with documentation, risk management, and dispute resolution and avoidance strategies. The course offers practical tools, roadmaps, and step-by-step guidance.
Transfer pricing should be a top priority. The OECD, United Nations, European Union, and many countries have revised—and continue to revise—their guidance on transfer pricing. Supply chains have been, and still are, under pressure, shifting from long and lean to agile and resilient. Business models of multinational enterprises (MNEs) are evolving into digital-first models. We’ve already seen BEPS 1.0, and now BEPS 2.0 is introducing proposals related to Pillar One and Pillar Two. These changes demand a new approach from both tax authorities and MNEs.
It’s critical that both parties can:
(i) understand and apply the latest transfer pricing guidance;
(ii) conduct detailed risk and functional analyses;
(iii) gain a clear understanding of how value is created; and
(iv) navigate the OECD’s three-tiered approach to transfer pricing documentation.
With so many developments, the risk of disputes is rising. For both MNEs and tax authorities, it’s essential to know what dispute resolution mechanisms are available and how to prepare in case a dispute arises.
- 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
- Explain the significance of international transfer pricing for multinational enterprise (MNE) groups and tax authorities
- Evaluate a country’s legal framework for transfer pricing, considering international standards and guidance (including the OECD Transfer Pricing Guidelines) and the role of tax treaties
- Analyze the challenges posed by the digital economy and the proposals under Pillar One and Pillar Two
- Identify various MNE operating models relevant to transfer pricing and apply a basic value chain analysis
- Recognize comparability factors, conduct a functional analysis, and outline the steps for performing a comparables search
- Identify transfer pricing methods, evaluate the pros and cons of each, and determine when and how to apply them
- Explain the purpose and content of transfer pricing documentation, including an understanding of international guidance
Online (QAS self-study course). Consists of 8 modules of 1-hour video lessons each. This course also includes recommended and optional reading materials and assignments to help apply knowledge in practice. Assessments are also included to test your overall understanding.
- 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
- Students
- This course may also be considered essential for individuals preparing for CIOT ADIT Module 1 – Principles of International Taxation and Module 3.03 - Transfer Pricing option. It may also benefit individuals preparing for CIOT ADIT Module 2.10 – United States option, though this course is not specifically designed for the ADIT. More information about this qualification can be found on the CIOT ADIT website.
This course is recommended for those with no or limited knowledge and experience with international transfer pricing. However, it is also suitable for those who have some experience with transfer pricing and wish to refresh or consolidate their understanding of the topic.
No advance preparation is necessary. All required study material is provided within the online training.
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: 14 hours 54 min
All mandatory course activities can be completed within the access period by dedicating approx. 1hour 45 min 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 continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have 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: 19
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.
Field of study: Taxes
Delivery format: Online - QAS Self Study
Delivery method: Online (QAS self-study). Consists of 8 modules of 1-hour video lessons each. Also includes recommended and optional reading materials and assignments to help apply knowledge in practice. Assessments are also included to test your overall understanding.
Course level: Introductory (basic)
This course was last reviewed in July 2024
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.
