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A highly interactive training course on
Principles of International Transfer Pricing
Training course overview
Taxation that is based on transfer pricing is becoming an important issue for many companies, whether U.S. based or foreign based. The regulations have sought to impose extensive general principles and guidelines that apply when the taxpayer selects the transfer pricing method. These methods impose penalties on an inappropriate choice of a transfer pricing method.
The goal of this Principles of International Transfer Pricing training course is to improve the fundamental knowledge of tax, accounting, and finance professionals on the main ideas and principles of transfer pricing. Additionally, it seeks to introduce the relationship between transfer pricing and more general technical tax, financial, and accounting sectors.
This training course will feature:
- Separate-entity approach
- The arm’s length principle
- The Cost-plus method
- The Transactional net margin method (TNMM)
- The Profit split method (PSM)
What are the goals?
By the end of this training course, participants will be able to:
- Improve the basic technical knowledge of transfer pricing and the significance of the arm's length principal
- Develop a holistic understanding of the important elements and stages of a typical transfer pricing analysis
- Analyze and develop an understanding of Domestic tax base erosion and profit shifting (DEPS) debate
- Understand the transfer pricing legislative framework
- Be advised of the recent developments and trends in the area of transfer pricing
Who is this training course for?
This training course will not only be of benefit to planning team members, but it will also provide useful insights and tools for other professionals in related fields, in particular, the course will greatly benefit:
- Financial accounting team members
- Cost and management accounting staff
- Finance managers
- Budget managers
- Commercial managers
- Capital investment and project team members
- Investment analysts and acquisition team members
- Risk managers
Course Outline
Day One: Introduction to Transfer Pricing
- Separate-entity approach
- What is transfer pricing?
- The significance of intra-group relations
- The importance of transfer pricing to states
- The importance of transfer pricing to MNE Groups
Day Two: The Legal Framework
- The international tax environment
- The arm’s length principle
- The alternative to the arm’s length principle: a global formulary apportionment
- The features of domestic transfer pricing regimes
- The importance of tax treaties (OECD and UN Models- Art. 9 and 25)
- The importance of the OECD Transfer Pricing Guidelines
Day Three: Transfer Pricing Methods
- The Comparable uncontrolled price (CUP) method
- The Resale price method (RPM)
- The Cost-plus method
- The Transactional net margin method (TNMM)
- The Profit split method (PSM)
- The Commodity rule
Day Four: Transfer Pricing Adjustments
- Compensating adjustments
- Primary adjustments
- Corresponding adjustments
- Secondary adjustments
- Repatriation
Day Five: Transfer Pricing Documentation
- Purpose of transfer pricing documentation
- Domestic transfer pricing documentation rules
- OECD Guidance (OECD Transfer Pricing Guidelines: Chapter V)
- Compliance issues
- United Nations Guidance
- Case studies and examples
The certificate
- Coventry Academy Certificate of Completion for delegates who attend and complete the training course