How to deal with international Transfer Pricing risk?
The global Transfer Pricing landscape is fraught with uncertainty and complexity. Transfer Pricing has drawn the attention of tax authorities and taxpayers worldwide. New rules, documentation requirements and different interpretation given to the OECD Transfer Pricing Guidelines by both tax authorities and multinationals have created ground for many disputes.
A significant Transfer Pricing issue facing multinational enterprises (MNEs) is Base Erosion and Profit Shifting (BEPS). On October 5, 2015, the OECD released the final BEPS reports to address perceived gaps in the international tax and transfer pricing rules in order to eliminate so-called ‘double non-taxation’ as well as no or low taxation, associated with practices that are perceived to segregate taxable income from the activities that generate them. The existing OECD Transfer Pricing Guidelines (TPG) are changing and policies that previously were compliant may need to be reviewed and in some cases, changes to the pricing made. It is now time for multinational enterprises to determine what practical implications they face and how they can best operate within this radically changed regulatory environment.
Major Transfer Pricing issues and concerns
This Transfer Pricing course will focus on major Transfer Pricing issues and concerns that all professionals involved in the complex area of Transfer Pricing will face such as: Business Restructuring and Valuation, Transfer Pricing Legislation and Guidelines, Documentation Requirements per region and per country, Transfer Pricing Project and Risk management, Transfer Pricing (pre-) Controversy Management, Design and Development of a Transfer Pricing Policy, types of Intercompany Transactions, Intellectual Property, Customs and, of course, the implications of BEPS for Transfer Pricing.
Target group of this Transfer Pricing course
This toplevel distance learning course on Transfer Pricing was designed to provide in-depth training for financial, tax and Transfer Pricing professionals who are interested in expanding their knowledge of the theory and practice of Transfer Pricing.
The course is relevant for Transfer Pricing Managers, (inter)national Tax Managers and firms, Finance Directors, Treasurers, Senior Executives with an interest in the latest developments in Transfer Pricing and Lawyers and accountants who serve their clients with Transfer Pricing issues and have to guide them in the ever-changing Transfer Pricing environment.
Note! Salary surveys among accountants, lawyers and economists reveil that practitioners with advanced Transfer Pricing knowlegde often earn more than twice as much as their counterparts with equivalent education and experience who lack Transfer Pricing expertise.
The course consists of 11 lessons, each of which will require about 4 hours of self-study. All course participants receive a Certificate of Participation.
Also available online through digital learning!
May we point you to the possibiity to also study this course online through digital learning? This is a service we offer free of charge if you order this distance learning course on Transfer Pricing. You will receive log-in details that will grant you access to the online learning environment for 1 year.
Transfer Pricing CPE credits
It should be noted that this Transfer Pricing course may qualify for CPE credits pursuant to the rules of a number of professional associations. Participants are encouraged to check with their professional association to determine eligibility in this respect.
Why a distance learning course on Transfer Pricing?
IMF Academy uses distance learning as an alternative and a complement to traditional training methods in order to make course materials accessible to large audiences worldwide. The greatest advantage is to be not confined by such constraints as geographical location and time. Thus, any client, anywhere in the world, can benefit from IMF Academy's distance learning programs at a time and place convenient to him or her. At the end of every distance learning course, you receive a certificate, acknowledging completion of the course.
For courses in Dutch, please visit www.imf-online.com.
Do you prefer training customized to your organisation? The Transfer Pricing course can also be organised in-company.
An in-house Transfer Pricing training:
- saves time and money;
- enables you to train in the comfort of your own working environment;
- can be arranged for groups of 6 people or more;
- will take place at a time chosen by and convenient for you; and
- sensitive issues can be openly discussed because there are no outsiders.
For more information on this Transfer Pricing course, the in-house possibilities or for other questions, please contact us directly at +31 (0)40 - 246 02 20 or send an e-mail to firstname.lastname@example.org.
Feedback of our Transfer Pricing participants
The Transfer Pricing course is assessed by participants with a 9-.
"The content is a good general overview of how Transfer Pricing works and simplifies the OECD guidelines in a more concise manner. Very good course, well planned and organized and thought out. I am very happy with the course. I gave me valuable insights on how HNE'e wok in relation to Transfer Pricing frameworks and the OECD guidelines."
Mrs. Mannerfelt, Accountant, MMCA Accounting Firm
"The course provides in-depth knowledge on Transfer Pricing related issues. It is a great chance to build up a strong base in Transfer Pricing. I appreciate the effort by TPA professionals and IMF in providing such a fine course."
Mrs. Shikha Mehta, Transfer Pricing Specialist, Novozymes South Asia Pvt. Ltd.
"The material was good, with useful references to OECD guidelines etc. It is a very thorough course, the 2-week interval gives enough time to study the material."
Mr. Fuglset, Business Controller, Kverneland Group
"Very interesting course."
"In my opinion everything was correct, all lessons were great. The easiest way of learning, especially for business people."
Ms. Kramar, Director, Krako-Revizija d.o.o.
"Very well written, easy to comprehend, with in-depth knowledge. The appendices were very useful."
Ms. Donbosco, Senior Accountant, Kanish & Partners LLP
"I found the material easy to process and well structured."
Mr. Smit, Lawyer, M. Partners
"This Transfer Pricing course was very good, well structured and detailed. I managed the clarify many concepts."
"It was a completely new topic for me and I enjoyed going through the course material and learning new concepts & practices."
"It was a great course and I will surely recommend othter people!"
"Good discussion of the subject matter."
Transfer Pricing: Introduction
- The context of the Transfer Pricing Process
- Basic Principles and Terminology, Methodologies
Documentation Requirements in the regulatory context of Transfer Pricing
- The OECD Transfer Pricing Guidelines
- Factors determining Comparability
- Introduction to Transfer Pricing Methods
Transfer Pricing Legislation and Guidelines
- US - the country of origin
- OECD - setting a global standard
- Latin America
- Trends in national, regional and global Documentation Standards
Design and Implementation of a Transfer Pricing Policy
- The Transfer Pricing Process
- Designing examples for Goods, Services and Intangibles
- Manual: how to design your Transfer Pricing system
- Checklist for taxpayers
Transfer Pricing Documentation: practical aspects
- Transfer Pricing Documentation – 3 concepts
- Use of the Master File in practice
- Use of country-specific Files in practice
- Best practices of Transfer Pricing Documentation
Transfer Pricing (pre-) Controversy Management
- Connectivity between 4 boxes
- Audit procedures
- Advance Pricing Agreements (APA)
- Mutual Agreement Procedure (MAP)
- EU Arbitration Convention
- Penalties and Interest
- Pre-Controversy Management Tools
- Case examples
Transfer Pricing Project and Risk Management
- Transfer Pricing Project Management
- Transfer Pricing Documentation and Risk Assessment
Types of inter-company Transactions
- List and examples of the most common inter-company Transactions
- List and examples of more complex inter-company Transactions
- Toolbox for analysis
Transfer Pricing of Intangibles
- The context of Transfer Pricing of Intangibles
- Labelling of Intangibles
- Identification of Intangibles
- Ownership of Intangibles
- Valuation of Intangibles
Business Restructuring and Valuation
- Definition of Business Restructuring
- Country-specific considerations
- Analysis of the situation before versus after Business Restructuring
- Valuation aspects of a Business Restructuring
- OECD Guidelines Chapter IX
- TR 2011/1
- Case Study
Transfer Pricing and Customs
- Differences and similarities between the 2 sets of rules
- The international debate on harmonization of Transfer Pricing and Customs Valuation
- Price and Profit Adjustments
Highly acclaimed instructors from Transfer Pricing Associates
Transfer Pricing Associates, part of the TPA Global group, is the leading independent provider of global Transfer Pricing services. TPA has offices and coverage in over 30 countries around the world and has an extensive practical knowledge and experience in a broad range of Transfer Pricing issues. TPA provides high quality Transfer Pricing advice and assistance to multinationals of all sizes, wherever they are located. For more details of the innovative services of TPA, please vist their website www.tpa-global.com. The editor of the Transfer Pricing course is
Steef Huibregtse is the Founding Member of TPA. He is a member of the Business Advisory Group to the OECDs Joint Working Group on Business Restructuring. Steef developed a Global Transfer Pricing Risk Management tool and developed a Global Benchmark Platform and was involved in more than 1.000 regional an global Transfer Pricing studies.
Should you also wish to make use of our free service digital learning in order to study the course online, please mention this in the remark field of the online registration form or check the box in the PDF registration form you can request via email@example.com. We will send you log-in details that will grant you access to the online learning environment for 1 year.
At the end of the distance learning course 'Transfer Pricing' you will receive a certificate of participation.
Should you wish to make use of our digital learning service (no additional costs charged) please mention this in the remark field of the online registration form (step 4) or check the box on the PDF registration form you can request via firstname.lastname@example.org.
*USD price is an approximate value. The actual USD price is based on the invoice date's exchange rate.