
apply cup in detail using reliable, comparable data from commercial databases to benchmark pricing for loans, royalties, and commodities, while leveraging internal and external comparables to defend arm's length documentation.
The lecture contrasts internal and external comparables, showing how related-party transfers are tested against similar unrelated transactions using databases and public data for transfer pricing.
Learn how to navigate a commercial database for transfer pricing, using keywords and international classification systems to filter 500+ agreements, compare royalty and service rates, and export results to Excel.
Explore external comparables and databases to benchmark transfer pricing margins, balancing internal comparables with public and commercial sources using strict comparability factors.
Select and refine potential comparables to build a reliable transfer pricing benchmark by sourcing internal and external data, applying objective criteria, and ensuring transparency, verifiability, and auditability.
Learn to apply transfer pricing methods, emphasizing cost-based and cup approaches, with function analysis and transaction delineation to reliably price intergroup services at arm's length.
Course Aims
The aim of this course is to ensure a student can choose and understand the appropriate TP method for controlled transactions, perform a comparability analysis and determine an arm’s length charge for Intra-Group Services.
For TP Methods, the student will fully understand how each method works, the specific conditions for a method to be applied and be able to perform the calculations required for each method.
The module further aims to provide the student with a thorough understanding of the comparability analysis, once the transaction has been delineated and the significant comparability factors taken into account. The comparability analysis is crucial to be able to determine the correction (if any) required to calculate an arm’s length price.
Lastly intra-group services will be studied, to ascertain when these services are rendered, to determine an arm’s length charge for these services and further conditions relating to the application of the OECD guidelines to intra-group services and low value-adding intra-group services.
On successful completion of this module, the student should be able to:
Compare/contrast the various transfer pricing methods that can be used to determine an arm’s length price.
Critically analyse the nine steps of a comparability analysis.
Evaluate the use of comparables in a comparability analysis.
Interpret OECD transfer pricing guidelines surrounding the charging for intra-group services.
Identify which intra-group services can be classified as low value-adding intra group services.
COURSE NOTE:
This course is Module 2 of a 4 Module course on Transfer Pricing. Each Module stands separately, however, we suggest that you complete all 4 courses in order to get the full benefit of these teachings.
Additional Modules in the whole course are:
Module 1 - Transfer Pricing Legal Framework
Module 2 (this course) - Sharing Corporate Resources
Module 3 - Transfer Pricing Specialised Areas
Module 4 - PE's & Compliance and Dispute Resolution