Transfer Pricing Fundamentals
What you'll learn
- Transfer Pricing
- Fundamental sources
- What is "multinational enterprise"
- What are "intragroup transactions"
- What is the "arm's length principle"
- What companies are "associated enterprises"
- Which transactions are controlled
- Comparability and five OECD comparability factors
- Why we need functional analysis
- What is entity characterization
- Risk analysis framework
- Transfer pricing methods
- Transfer pricing documentation
- Nothing specific - but a very basic understanding of finance/tax is helpful
You probably heard about multinationals' tax avoidance, tax heavens and cross-border profit-shifting. In the last decade, many multinationals were accused of tax dodging - often, using something called "transfer pricing". But is transfer pricing bad? What is it, actually?
The course gives an overview of international transfer pricing rules and principles and covers the following topics:
1) What is transfer pricing, associated enterprises and controlled transactions?
2) Why is it relevant from a tax perspective?
3) How multinationals can use transfer pricing for tax avoidance?
4) What are transfer pricing rules?
5) What is the arm's length principle and where it comes from?
6) What is comparability?
7) What is a functional analysis and why is it needed?
8) What are five OECD transfer pricing methods and when are they used?
9) What is transfer pricing documentation?
The course will be useful for every finance, accounting and tax professional who wants to understand what transfer pricing is about and where modern transfer pricing rules come from. If you need to deal with transfer pricing or intragroup transactions, review the transfer pricing documentation or policies, cooperate with consultants - this course is for you!
The course will be especially useful for someone preparing for a career in transfer pricing or international tax.
The course is not country-specific, as the principles explained in the course are universal around the world.
Who this course is for:
- Finance and business professionals interested in transfer pricing and international tax
- Someone who has to deal with transfer pricing and needs a basic understanding of key transfer pricing concepts
- Finance and accounting folks dealing with intragroup transactions
- International tax specialists considering move to transfer pricing field
Borys Ulanenko is an international tax professional with more than seven years’ experience in transfer pricing. He started his career at KPMG and moved to Royal Dutch Shell in 2016. Currently, Borys manages the team supporting the MNE's transfer pricing matters worldwide, including transfer pricing documentation, audits, and APAs.
Borys often lectures on transfer pricing. He has been delivering specialized seminars and lectures since 2014 and has developed several onboarding programs for new colleagues with different backgrounds.
In 2020, Borys established StarTax Education company - an innovative education startup in the field of taxation that combines strong technical tax expertise, a passion for teaching, and innovative educational technologies.