Training Course: Comprehensive Transfer Pricing Training

Introduction

The Advanced Transfer Pricing Course is a comprehensive program designed to provide participants with in-depth knowledge and practical skills related to transfer pricing issues specifically focused on intangibles and other related topics. This advanced-level course is tailored for professionals who already possess a solid understanding of transfer pricing fundamentals and wish to explore the complexities surrounding intangible assets, intellectual property, and other key aspects of transfer pricing. Through a combination of theoretical discussions, case studies, and interactive exercises, participants will enhance their expertise in managing transfer pricing challenges related to intangibles within multinational enterprises.

Objectives

• Develop a deep understanding of transfer pricing principles and methodologies related to intangible assets.
• Gain insights into the identification, valuation, and management of intangibles for transfer pricing purposes.
• Acquire knowledge of the legal and economic aspects associated with intangibles in transfer pricing.
• Understand the challenges and best practices for documenting and defending transfer pricing arrangements involving intangibles.
• Learn how to analyze and address transfer pricing disputes and controversies specific to intangibles.
• How to allocate profits
• Explore the latest trends and developments in international transfer pricing regulations related to intangibles.
• Apply practical tools and techniques to optimize transfer pricing outcomes for transactions involving intangibles within multinational enterprises.
• Permanent establishments

Course Outline

Day 1

Transfer Pricing 

• Review of transfer pricing fundamentals and arm's length principle.
• Overview of intangible assets and their importance in transfer pricing.
• Types of intangibles and their characteristics.
• Legal and economic considerations related to intangibles in transfer pricing.

Day 2

 Valuation of Intangibles for Transfer Pricing Purposes 

• Methods and approaches for valuing intangibles.
• Comparable uncontrolled price (CUP) method for intangibles.
• Income-based valuation methods: profit split method and royalty relief method.
• Cost-based methods for intangibles.

Day 3

 Intangibles in Transfer Pricing Documentation and Compliance

• Transfer pricing documentation requirements for intangibles.
• Best practices for documenting intangibles and their contributions.
• Intangible-related transactional analyses and benchmarking.
• Addressing risk and control functions related to intangibles.

Day 4

 Transfer Pricing Disputes and Controversies Involving Intangibles

• Common transfer pricing issues and disputes related to intangibles.
• Analyzing and addressing transfer pricing controversies specific to intangibles.
• Advanced dispute resolution mechanisms for intangible-related transfer pricing issues.
• Recent case studies and legal developments related to intangibles.

Day 5

 Emerging Trends and Practical Applications

• BEPS (Base Erosion and Profit Shifting) and its impact on intangibles in transfer pricing.
• Digital economy, cloud computing, and intangible-related challenges.
• Practical case studies and group exercises focused on intangibles.
• Strategies for optimizing transfer pricing outcomes involving intangibles.

Benchmarking for Intangibles in Transfer Pricing

• Importance of benchmarking in transfer pricing involving intangibles.
• Methods and approaches for benchmarking intangible transactions.
• Comparable companies analysis for intangibles.
• Selection and application of appropriate comparables for intangibles.
• Practical considerations and challenges in benchmarking intangibles.