Advanced Transfer Pricing

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. This advanced-level course is tailored for professionals who already possess a solid understanding of transfer pricing fundamentals and wish to delve deeper into the complex aspects of transfer pricing planning, documentation, and dispute resolution. Through a combination of theoretical discussions, case studies, and interactive exercises, participants will enhance their expertise in managing transfer pricing issues within multinational enterprises.

Objectives

• Gain a deep understanding of advanced transfer pricing concepts, methodologies, and techniques.
• Develop the skills necessary to design and implement effective transfer pricing strategies.
• Acquire knowledge of transfer pricing documentation requirements and best practices.
• Understand the intricacies of transfer pricing compliance and risk management.
• Learn how to analyze and address transfer pricing disputes and controversies.
• Explore the latest trends and developments in international transfer pricing regulations.
• Apply practical tools and techniques to optimize transfer pricing outcomes within multinational enterprises.

Course Outline

Day 1

 Advanced Transfer Pricing Concepts and Methodologies

• Review of transfer pricing fundamentals and arm's length principle.
• Advanced transfer pricing methods: profit split method, transactional net margin method, and others.
• Comparability analysis: identifying and adjusting for differences between controlled and uncontrolled transactions.
• Addressing intangibles, cost-sharing arrangements, and intra-group services.

Day 2

 Transfer Pricing Planning and Design

• Strategic transfer pricing considerations.
• Creating and implementing effective transfer pricing policies.
• Advanced transfer pricing planning techniques.
• Transfer pricing and business restructurings.

Day 3

 Transfer Pricing Documentation and Compliance

• Transfer pricing documentation requirements: master file, local file, and country-by-country reporting.
• Best practices for preparing and maintaining transfer pricing documentation.
• Transfer pricing compliance challenges and risk management strategies.
• Transfer pricing audits and tax authority expectations.

Day 4

 Transfer Pricing Dispute Resolution

• Transfer pricing controversies and dispute resolution mechanisms.
• Mutual agreement procedure (MAP) and advance pricing agreements (APAs).
• Transfer pricing litigation and alternative dispute resolution methods.
• Managing transfer pricing disputes with tax authorities.

Day 5

 Emerging Trends and Practical Applications

• BEPS (Base Erosion and Profit Shifting) and its impact on transfer pricing.
• Digital economy and transfer pricing challenges.
• Transfer pricing in specific industries or transactions.
• Practical case studies and group exercises.