Course Introduction

For many businesses, whether they are situated in the United States or abroad, taxation that is based on transfer pricing is becoming a significant concern. Extensive general rules and standards that apply when the taxpayer chooses the transfer pricing technique have been attempted to be imposed by the regulations. These procedures impose sanctions for selecting a transfer pricing mechanism improperly.

The Fundamentals of Transfer Pricing Strategies training course aims to increase tax, accounting, and finance professionals' fundamental understanding of the central concepts and tenets of transfer pricing. The relationship between transfer pricing and more broadly technical tax, financial, and accounting sectors is also intended to be introduced.

This GLOMACS training course will feature:

• The structure of Multinational Companies (MNC’s)
• The Profit Split Method (PSM)
• The Cost-Plus Method
• Separate-Entity Approach
• The Arm’s Length Principle
• The Transactional Net Margin Method (TNMM)

Objectives

By the end of this Fundamentals of Transfer Pricing Strategies training course, participants will be able to: 

• Acquire basic technical knowledge of transfer pricing
• Appreciate the importance of the arm's length principal 
• Identify the different stages of a typical transfer pricing analysis
• Developing a high-level appreciation of the transfer pricing including tax areas and opportunities for multinationals
• Analyze the current transfer pricing legislative framework
• Be updated on recent developments of transfer pricing

Training Methodology

The Fundamentals of Transfer Pricing Strategies training course leader will deploy a full range of dynamic and interactive training methods in a carefully balanced programme of tutor presentations supported by real examples and case experiences of individual issues. Also, delegates will work in groups on case studies to develop their skills in the key tools and techniques of this subject.

Organisational Impact

This Oxford Management Centre training course is of direct relevance to the Finance and Accounting and as a result the organizations will benefit greatly from their employee’s participation. The organization will gain from:

• More effective financial support for Taxation purposes
• Greater relevance and reliability of Cross Accounting Practices
• More strategic thinking and focus on global performance of the firm
• More effective use of taxation and accounting methods
• Preparation of staff for better judgement and appreciation of cross countries accounting and taxation techniques

Personal Impact

This Fundamentals of Transfer Pricing Strategies training course will be of personal benefit to delegates by providing you with:

• A better understanding of the context and importance of transfer pricing
• Greater awareness of current Tax treaties
• Increased understanding of inter-group transactions for tax optimization
• Be aware of the recent developments and trends from regulatory framework of transfer pricing
• Greater ability to mitigate taxation issues and proposing better techniques of transfer pricing

Who Should Attend?

This training course will not only be of benefit to Taxation 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

Course Outline

DAY 1

Introduction to Transfer Pricing

• The importance of transfer pricing to states
• The importance of transfer pricing to MNE Groups
• Separate-entity approach
• What is transfer pricing?
• The significance of intra-group relations

DAY 2

The Legal Framework

• Understanding the international tax environment
• What is the arm’s length principle?
• The global formulary apportionment
• Domestic transfer pricing regimes
• Tax treaties: the OECD and UN Models
• The importance of the OECD Transfer Pricing Guidelines

DAY 3

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 4

Transfer Pricing Adjustments

• Compensating adjustments
•  Primary adjustments
•  Corresponding adjustments
•  Secondary adjustments
•  Repatriation  

DAY 5

Transfer Pricing Documentation

• Transfer pricing documentation: purpose and uses
• The rules of Domestic transfer pricing documentation
•  OECD Guidance
• United Nations Guidance