
Explore intragroup transactions within multinational groups and learn how transfer pricing sets prices for goods and services exchanged between parent and subsidiary entities, including manufacturing and research and development flows.
Identify entities within a multinational group by establishing tax functional profiles and primary functions, then determine tested parties and suitable comparables for transfer pricing.
apply the resale price method to arrive at transfer prices by subtracting a gross margin from the final resale price to unrelated customers, ensuring arms-length margins.
Shows how transfer pricing audits assess arm's length compliance through documentation requests, local file and master file considerations, and extensive fact-finding, leading to initial and final assessments and possible adjustments.
Discover next steps in transfer pricing with readings on arm's length principle, the oil city transit pricing guidelines, the United Nations Transit Pricing Manual, and the World Bank handbook.
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.