Introduction:

Transfer pricing strategies refer to the methods multinational enterprises use to determine the pricing of transactions between their related entities across borders. These strategies are essential for complying with international tax laws, allocating profits fairly, and avoiding double taxation. This program introduces the core principles of transfer pricing, including its legal foundations, pricing methods, and documentation requirements. It is designed to help professionals understand how to apply transfer pricing strategies effectively and in alignment with global standards such as the OECD guidelines.

Program Objectives:

By the end of this program, participants will be able to:

Understand the concept and significance of transfer pricing.
Apply key transfer pricing methods by international standards.
Interpret the OECD Transfer Pricing Guidelines and related legal frameworks.
Prepare and manage compliant transfer pricing documentation.
Implement necessary adjustments to ensure alignment with regulatory expectations.

Targeted Audience:

Tax and financial accounting professionals.
Finance and cost management officers.
Budget and commercial supervisors.
Investment analysts and acquisition teams.
Project finance specialists.
Risk and compliance managers.

Program Outline:

Unit 1:

Introduction to Transfer Pricing:

Definition and relevance of transfer pricing.
Role of intra-group transactions in multinational enterprises.
Separate-entity vs. unified approach.
Strategic significance for tax jurisdictions and MNEs.

Unit 2:

Legal and Regulatory Framework:

Understanding the global tax environment.
The arm’s length principle.
Overview of OECD and UN Model Tax Conventions.
Domestic legal frameworks for transfer pricing.
Importance of OECD Transfer Pricing Guidelines.

Unit 3:

Transfer Pricing Methods:

Comparable Uncontrolled Price (CUP) method.
Resale Price Method (RPM).
Cost-Plus Method.
Transactional Net Margin Method (TNMM).
Profit Split Method (PSM).
Specific pricing rules for commodities.

Unit 4:

Transfer Pricing Adjustments:

Primary and secondary adjustments.
Compensating adjustments.
Corresponding adjustments and dispute resolution.
Issues related to repatriation and double taxation.

Unit 5:

Transfer Pricing Documentation and Compliance:

Purpose and importance of transfer pricing documentation.
Local file and master file requirements.
OECD documentation standards.
United Nations practical manual and developing country considerations.

Fundamentals of Transfer Pricing Strategies