Transfer Pricing
Gain an understanding of basic transfer pricing issues and how to deal with them, then move onto more complex subjects such as comparability factors, business restructuring, PE existence, PE profit intangibles and running an in-house transfer pricing function. Our 3 one-day modules can be taken separately or as a series.
Overview
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Course structure
Who is it for?
All needing an incisive insight into the mechanics of transfer pricing, including management and financial accountants, operational managers, financial managers and their junior tax staff in large and medium sized groups in all sectors.
What will you learn?
Learning Outcomes: Module 1 - Fundamentals
By the end of this course, you will be able to:
Explain the fundamentals of transfer pricing and its alignment with corporate objectives
Understand and apply the main transfer pricing methods in practice
Conduct functional and economic analyses, including comparability studies
Evaluate intra-group services, head office expenses, cost sharing, and cost contribution arrangements
Prepare and review transfer pricing documentation in line with regulatory expectations
Recognise governance and control considerations in transfer pricing
Manage adjustments, dispute settlements, audits, and associated risks
Assess emerging trends and the future direction of transfer pricing regulation
Course Coverage
This course will cover:
What is transfer pricing?
Corporate objectives
Transfer pricing methods
Functional analysis
Economic analysis and comparability studies
Intra-group services and head office expenses
Cost sharing and cost contribution arrangements
Documentation
Transfer pricing governance and control
Adjustments and dispute settlements
Audits and how to manage them
Risk management
Looking to the future
Who is it for?
Financial directors and controllers with some knowledge of transfer pricing needing an appreciation of the operational risk and strategic opportunitiesTax specialists seeking an understanding of the advanced elements of transfer pricing
Delegates attending this course should either have attended Transfer Pricing Module 1 - Fundamentals or have a good grasp of basic transfer pricing concepts.
Delegates may also be interested in the follow-on module Transfer Pricing Module 3 - Operational Effectiveness
What will you learn?
Learning Outcomes: Module 2 - Planning & Control
By the end of this course, you will be able to:
Understand the key comparability factors in transfer pricing and how they are applied
Assess the transfer pricing implications of business restructuring and permanent establishment (PE) existence and profit allocation
Analyse the treatment of intangibles and intellectual property across jurisdictions, including challenges in ‘interesting countries’
Evaluate thin capitalisation issues and their impact on transfer pricing
Manage the operation of an in-house transfer pricing function effectively
Identify common transfer pricing pitfalls and learn how to avoid them
Consider the role of Advance Pricing Agreements (APAs) within broader tax planning and strategy
Apply transfer pricing principles to treasury functions
Course Coverage
This course will cover:
Comparability factors
Business restructuring
PE existence and PE profit
Intangibles and intellectual property
“Interesting countries”
Thin capitalisation
Running an in-house transfer pricing function
Common snags and mistakes — and how to avoid them
To APA or not to APA? Planning and tax strategy
Transfer pricing in the treasury function
Who is it for?
The course is designed for Tax Professionals working in-house who need to deal with transfer pricing but also for advisers seeking to understand the dynamics of a transfer pricing team.
What will you learn?
Learning Outcomes: Module 3 - Operational Effectiveness
By the end of this course, you will be able to:
Manage and lead a transfer pricing team effectively
Engage with stakeholders across the business to ensure alignment on transfer pricing policies
Implement and monitor the necessary controls to ensure transfer pricing policies are adhered to in practice
Understand recent changes in requirements arising from OECD recommendations
Course Coverage
This course will cover:
Managing a transfer pricing team
Engaging with other stakeholders in the organisation
Designing and implementing effective transfer pricing controls
OECD-driven changes to transfer pricing requirements
Why choose BPP for technical skills?
Ways to pay
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