A Highly Interactive Training Course On

Principles of International Transfer Pricing

A Practical Guide to your Cross Countries Taxes’ Optimization

Principles of International Transfer Pricing
Course Schedule

CLASSROOM

21-25 Apr 2025
Dubai
$5,950
24-28 Nov 2025
Dubai
$5,950
Certificate
  • Coventry Academy Certificate of Completion for delegates who attend and complete the training course

 

Training Overview

Training Overview

Transfer pricing, especially in the context of international transactions, has emerged as a critical issue impacting both U.S.-based and foreign-based companies. Regulatory frameworks have increasingly focused on establishing comprehensive guidelines and principles governing the selection of transfer pricing methods. Incorrect application of these methods can lead to significant penalties for taxpayers.

The Principles of International Transfer Pricing training course aims to enhance the foundational knowledge of tax, accounting, and finance professionals regarding the key concepts and principles of transfer pricing. It is designed to elucidate the interplay between transfer pricing and broader technical areas in tax, finance, and accounting.

Key components of this training course include:

  • Exploring the separate-entity approach in transfer pricing
  • Understanding the arm’s length principle and its application
  • Detailed examination of the Cost-plus method
  • Introduction to the Transactional Net Margin Method (TNMM)
  • Insights into 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

The Course Content

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