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:
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
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
- 00:25Introduction
Instructor
![Quebiko Training](data:image/svg+xml,%3Csvg xmlns="http://www.w3.org/2000/svg" viewBox="0 0 64 64"%3E%3C/svg%3E){kind=avatar}
- 4.2 Instructor Rating
- 25 Reviews
- 96 Students
- 5 Courses
QUEBIKO is part of The International Institute for Tax & Finance (I/I/T/F).
I/I/T/F specialises in post graduate courses in fields of cross-border taxation. The IITF started in 2005 as a small short course training institution, but in 2008 took the move to partner with international universities offering full post graduate qualifications focussing primarily.
The IITF faculty is made up of a panel of cross-border taxation professionals who are actively involved in their specialised fields. We believe that working with professionals allows our students to be exposed to real information as it happens.