Transfer Pricing

This Module 3 Transfer Pricing is designed to provide participants with a deep understanding of transfer pricing principles, methodologies, and compliance strategies, ensuring they are well-equipped to navigate the evolving global tax landscape.

 

The course begins with an introduction to the fundamentals of transfer pricing, covering Article 9 of the OECD and UN Model Convention, key comparability analyses, risk allocation, value chain analysis, and FAR (Functions, Assets, and Risks) assessment. Students will explore various transfer pricing methods, including traditional (CUP, cost-plus, resale price) and transactional (TNMM, profit split) methods.

 

Advanced topics focus on transfer pricing for financial transactions, intragroup services, business restructuring, cost-sharing arrangements, and intangible assets. Special topics include BEPS 2.0, Pillar Two Solution, and sector-specific transfer pricing applications, such as those in commodities, automotive, banking, insurance, and oil and gas industries.

 

Students will gain practical skills in benchmarking studies, preparing transfer pricing documentation (Master File & Local File), and managing tax audits and disputes. The course also covers mutual agreement procedures - MAP and advance pricing agreements – APA and equips participants with the tools to mitigate tax risks and prevent economic double taxation.

 

After completing this Module, students will:

• Develop expertise in analyzing and applying transfer pricing regulations.

• Master key pricing methodologies and sector-specific transfer pricing strategies.

• Gain practical experience in preparing TP documentation and handling tax audits.

• Understand the impact of BEPS 2.0 and evolving global tax frameworks.