Transfer Pricing Master Class (Part 2)
4.0 (1 rating)
Course Ratings are calculated from individual students’ ratings and a variety of other signals, like age of rating and reliability, to ensure that they reflect course quality fairly and accurately.
20 students enrolled

Transfer Pricing Master Class (Part 2)

Sharing Corporate Resources
4.0 (1 rating)
Course Ratings are calculated from individual students’ ratings and a variety of other signals, like age of rating and reliability, to ensure that they reflect course quality fairly and accurately.
20 students enrolled
Created by Tax Tribe
Last updated 2/2020
English
English [Auto]
Current price: $34.99 Original price: $49.99 Discount: 30% off
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This course includes
  • 7.5 hours on-demand video
  • 1 article
  • 1 downloadable resource
  • Full lifetime access
  • Access on mobile and TV
  • Certificate of Completion
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What you'll learn
  • Transfer Pricing Methods (Traditional Methods, Profit Split Method, TNMM)
  • Comparability Analysis (OECD, Secret Comparables, Comparability Adjustments)
  • Critically analyse the nine steps of a comparability analysis.
  • Evaluate the use of comparables in a comparability analysis.
  • Intra-Group Services
  • Compare/contrast the various transfer pricing methods that can be used to determine an arm’s length price.
  • Intra-Group Services relating to the application of OECD guidelines
  • 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.
Requirements
  • Knowledge of International Taxation principles
  • Basic understanding of Transfer Pricing
Description

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:

  1. Compare/contrast the various transfer pricing methods that can be used to determine an arm’s length price.

  2. Critically analyse the nine steps of a comparability analysis.

  3. Evaluate the use of comparables in a comparability analysis.

  4. Interpret OECD transfer pricing guidelines surrounding the charging for intra-group services.

  5. 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

Who this course is for:
  • Transfer Pricing Specialists
  • Finance Directors
  • Group Tax Directors
  • Heads of Corporate Tax
  • Tax Accountants
  • Lawyers
  • Heads of Transfer Pricing
  • Senior Tax Managers
  • Senior Executives
  • Accountants
Course content
Expand all 25 lectures 07:17:10
+ TP Methods - Traditional Methods (Including CUP)
3 lectures 51:27
Part 2 - CUP in detail
21:19
Part 3 - Using CUP - Advantages & Disadvantages
09:41
+ TP Methods - Profit Split Method
3 lectures 49:37
Profit Split Method Part 1
18:26
Profit Split Method Part 2
20:10
Profit Split Method Part 3
11:01
+ TP Methods - TNNM Method with Database Examples
2 lectures 01:25:55
Part 1 - Royalty Range Example
44:29
Part 2 - ONESource Example
41:26
+ Comparability Analysis Part 1 - Introduction
4 lectures 01:25:31
Part 1 - Introduction Part 1
24:11
Part 2 - Introduction Part 2
17:47
Part 3 - Introduction 3
16:12
Part 4 - Database Introduction
27:21
+ Comparability Analysis Part 2
3 lectures 41:28
Part 1 - Intro & Databases
15:19
Part 2 - Limitations in available comparables
20:15
Part 3 - Potential Comparables
05:54
+ Comparability Analysis Part 3
3 lectures 43:43
Part 1 - Types of adjustments & working capital adjustments
17:03
Part 2 - Purpose of Adjustments
19:42
Part 3 - Compliance Issues
06:58
+ Intra Group Services Part 1
3 lectures 30:37
Part 1 - Introduction
05:46
Part 2 - Has Intra Group Service been rendered?
15:07
Part 3 - Determining arms length charge
09:44
+ Intra Group Services Part 2
3 lectures 48:26
Part 1 - Intra Group Services - Special Considerations
14:45
Part 2 - Methods
20:14
Part 3 - Final remarks on Intra Group Services
13:27