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.

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 Inter-company Transactions
• Intangibles
• Customs
• The implications of BEPS for Transfer Pricing

For who?

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 many other professionals.

Note! Salary surveys among accountants, lawyers and economists reveal that practitioners with advanced Transfer Pricing knowledgee often earn more than twice as much as their counterparts with equivalent education and experience who lack Transfer Pricing expertise.

CPE credits

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.

Prerequisites

There are no specific requirements for successfully studying this toplevel Transfer Pricing course.

Study time

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 for higher-educated individuals.

Language

This Transfer Pricing course is only available in English. 

Why a distance learning course?

IMF Academy uses distance/online 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. 

LESSON I
Transfer Pricing – introduction

• Context of the Transfer Pricing process
• Basic principles and terminology, methodologies

LESSON II
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)

LESSON III
Transfer Pricing legislation and guidelines

• Advanced Pricing Agreements (APA)
• US: the country of origin
• OECD: setting a global standard
• Europe
• Australia
• Asia
• Latin America
• Trends in national, regional and global documentation standards

LESSON IV
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

LESSON V
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

LESSON VI
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

LESSON VII
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

LESSON VIII
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

LESSON IX
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

LESSON X
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

LESSON XI
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