Toplevel course on Transfer Pricing documentation, BEPS, new rules and legislation, Transfer Pricing Guidelines, Business Restructuring and Valuation, Controversy Management, and other major Transfer Pricing issues and concerns
Transfer Pricing – mode of study
Option 1: Distance learning course (incl. digital learning)
Option 2: In-company course, customized for your organisation
International Transfer Pricing risk – how to deal with?
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 multinational enterprises (MNEs) are facing now is Base Erosion and Profit Shifting (BEPS). The existing OECD Transfer Pricing Guidelines are changing and policies that previously were compliant may need to be reviewed and in some cases, changes to pricing have to be 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.
Transfer Pricing – major 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, ofcourse, the implications of BEPS for Transfer Pricing.
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, and other professionals.
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.
This Transfer Pricing course may qualify for CPE credits pursuant to the rules of many professional associations in many countries. Please check with the professional association(s) in your country to determine eligibility in this respect.
There are no specific requirements for successfully studying this toplevel Transfer Pricing course.
The distance learning course on Transfer Pricing consists of 11 lessons, each of which will require on average 4 hours of self-study.
Level of the course
The Transfer Pricing course is developed on a higher educational level.
This Transfer Pricing course is only available in English.
Transfer Pricing – certificate
You receive a personal certificate, acknowledging completion of this Transfer Pricing course.
Why a distance learning course?
IMF Academy uses distance learning as an alternative and a complement to traditional in-class trainings in order to make high-level course materials accessible to large audiences worldwide. The greatest advantage is not to be confined by such constraints as geographical location and time. 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 personal certificate, acknowledging completion of the course.
Advantages of this distance learning course
The distance learning course on Transfer Pricing has numerous advantages for you:
- You may compare the study material of this course with the information you would get from a 6-day in-class training on Transfer Pricing
- All lessons are equipped with cases, best practices and literature references
- You can study the course where, whenever and in the pace you like
- All lessons are equipped with questions (and answers) to check your knowledge
- The study material will serve as a reference work you will often use
- No travel expenses and accommodation cost, and no loss of working days
- Studying a distance learning course is far more cheaper compared with an in-class training. Estimations are that you/your company save 40%-60%.
Transfer Pricing – also available as digital learning
Do you wish to study the Transfer Pricing course online? We offer you this extra service free of charge. You will receive a personal log-in code for the period of one year. You will also receive the full study material on paper.
Transfer Pricing – feedback
The Transfer Pricing course is evaluated by participants with a 9. Please see some remarks of former participants:
"Excellent course! Up to date information. Very useful course material and tools. Very professional, effective and timely communication."
Nugmanov, Manager international Tax and Transfer Pricing, The Gap Inc.
"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. It gave me valuable insights on how MNEs work in relation to Transfer Pricing frameworks and the OECD guidelines."
Mannerfelt, Accountant, MMCA Accounting Firm
"It is one of the few distance learning courses on Transfer Pricing with content very carefully organized to meet the learner's intellectual need on the topic and stay abreast with the increased pace of change in the tax world.
In the Middle East, the area of Transfer Pricing is fairly new and is slowly finding its way in the local tax laws. The course rightly captures the understanding of the concept of Transfer Pricing as seen in far more advanced economies and enables users to adapt the knowledge and techniques in developing economies with growing Transfer Pricing trends."
Leandre Santamaria, Tax Specialist, FedEx
"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."
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."
Fuglset, Business Controller, Kverneland Group
"The course helped me to understand what is involved in TP policy. Very useful in my current responsibility."
"Very interesting course."
"In my opinion everything was correct, all lessons were great. The easiest way of learning, especially for business people."
Kramar, Director, Krako-Revizija d.o.o.
"Very well written, easy to comprehend, with in-depth knowledge. The appendices were very useful."
Donbosco, Senior Accountant, Kanish & Partners LLP
"I found the material easy to process and well structured."
Smit, Lawyer, M. Partners
"This Transfer Pricing course was very good, well structured and detailed. I managed to 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 the course to other people!"
"Good discussion of the subject matter."
"An excellent course with a lot of in-depth analysis."
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Transfer Pricing – in-company (and customized)
Do you prefer an in-house and customized course on Transfer Pricing? An in-house course on Transfer Pricing, customized for your organisation, has many advantages and:
- Saves you and your colleagues time, travel and accomodation costs
- Enables you to train in the comfort of your own working environment
- Can be arranged at a time convenient for you
- Sensitive issues can be openly discussed because there are no outsiders
- Can be arranged for groups with a minimum of 5 people
For more information on this Transfer Pricing course, the in-house possibilities or for any other question, please contact us directly at +31 (0)40 – 246 02 20 or send an e-mail to firstname.lastname@example.org.
TRANSFER PRICING – CONTENT
Transfer Pricing – introduction
- Context of the Transfer Pricing process
- Basic principles and terminology, methodologies
Documentation requirements in the regulatory context of Transfer Pricing
- OECD Transfer Pricing Guidelines
- Factors determining comparability
- Introduction to and application of Transfer Pricing methods: Comparable Uncontrolled Price (CUP) method, Resale Price Method (RPM), Cost Plus Method (CPM), Transactional Profit Split Method (TPSM), Transactional Net Margin Method (TNMM)
Transfer Pricing legislation and guidelines
- Advanced Pricing Agreements (APA)
- US: the country of origin
- OECD: setting a global standard
- Latin America
- Trends in national, regional and global documentation standards
Transfer Pricing policy – design and implementation
- 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 rules
- Centralized documentation, local documentation, hybrid approach, other documentation issues
- G20/OECD BEPS Action 13
- Use of the master file in practice
- Use of country-specific files in practice (autonomous and complementary approach)
- 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 charges
- Pre-controversy management tools
- Case examples
Transfer Pricing project and risk management
- Transfer Pricing process
- From Transfer Pricing risks to tax provision
- Practical considerations for a Transfer Pricing project
- 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 (legal or economic)
- Valuation of intangibles
- Examples: valuation of customer list and valuation of content-related intangibles
Business restructuring (BR) and valuation
- Definition of business restructuring
- Country-specific considerations
- Analysis of the situation before versus after business restructuring
- Valuation aspects of a business restructuring
- Case Study
Transfer Pricing and customs
- Differences and similarities between the 2 sets of rules
- International debate on the harmonization of Transfer Pricing and customs valuation
- Price and profit adjustments: alignment procedures in the US and the EU
Top Transfer Pricing specialists/instructors
Your highly acclaimed instructors are all working at Transfer Pricing Associates (TPA) Global. Your chief editor is:
Steef Huibregtse is the founder and CEO of TPA Global. Steef has more than 30 years experience in the area of transfer pricing strategy, value chain analysis, digital transformation and data factories, risk management, design, documentation, controversy management and implementation. Steef recently launched a global tax controversy platform with the 'best in class' litigators and mediators. Steef himself frequently acts as expert witness on global/regional Transfer Pricing/BEPS disputes.
Start date(s)The distance learning course on ' Transfer Pricing' starts on 19 September 2019 and 17 October 2019 Since this is a distance learning course, it is also possible to start on any other date you desire. On the registration form you can indicate your preferred start date, choose the interval for receiving the paper lessons and indicate whether you wish to make use of our free digital learning service in order to study the course online. You will receive the full course in one shipment. We advise you to study 1 lesson per week, each of which will require about 4 hours of self-study.
N.B. when you live in The Netherlands, you can choose to receive the first lesson on the date of your choice, whereafter we will periodically send you one lesson (depending on the interval you chose). However, if you choose to study the Transfer Pricing course online, you will receive the full course in one shipment also.
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