It is often said that transfer pricing is not an exact science, hence to develop an understanding of transfer pricing principles and methodologies, consideration of their practical application is considered paramount. This intermediate level 4 and a 1/2 day course introduces participants to transfer pricing principles and methodologies and then covers the application of these principles and methodologies to specific categories of intra-group dealings. These sessions are complemented by practical sessions that cover the application of the principles and methodologies in practice. The focus of this practically orientated course is on the requirements of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the issues that can arise in the application of these requirements.
Topics Covered - Introduction to Transfer Pricing
- Transfer Pricing Methods
- Comparability Analysis
- Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes
- Transfer Pricing Documentation
- Intra-Group Services and Cost Contribution Arrangements
- Intra-Group Finance Transactions
- Transfer Pricing and Intangibles
- Managing the Customs-Transfer Pricing Nexus
- Transfer Pricing Risk Management
- Transfer Pricing and Business Restructuring
- Case Studies
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