Legal / Law Training Course on Transfer Pricing & International Tax Law

Module 1: Introduction to Transfer Pricing and International Taxation
Overview:
Provides foundational knowledge of transfer pricing, cross-border taxation, and regulatory frameworks.
Key Topics:
Definition, purpose, and principles of transfer pricing
Arm’s length principle and OECD guidelines
Overview of international tax law frameworks
Regulatory authorities and enforcement mechanisms
Key stakeholders: taxpayers, regulators, and auditors
Comparative analysis of transfer pricing regimes
Practical Focus:
Case study: Assessing the applicability of OECD transfer pricing principles in different jurisdictions.

Module 2: Transfer Pricing Methods and Documentation
Overview:
Covers the methodologies for setting and documenting transfer prices.
Key Topics:
Comparable uncontrolled price (CUP) method
Resale price, cost-plus, transactional net margin, and profit split methods
Selection of appropriate transfer pricing methods
Transfer pricing documentation requirements and compliance
Country-by-country reporting obligations
Preparing defensible documentation for audits
Practical Focus:
Exercise: Develop a transfer pricing policy for a hypothetical multinational company.

Module 3: Cross-Border Transactions and Tax Planning
Overview:
Examines structuring international transactions to comply with transfer pricing rules.
Key Topics:
Intercompany transactions: goods, services, intellectual property, and financing
Cross-border tax implications and planning strategies
Tax treaties, double taxation agreements (DTAs), and treaty benefits
Managing withholding taxes and indirect taxation
Risk assessment and compliance planning
Case studies of cross-border tax planning
Practical Focus:
Workshop: Structure intercompany transactions to optimize tax efficiency while ensuring compliance.

Module 4: Transfer Pricing Compliance and Risk Management
Overview:
Focuses on ensuring compliance and mitigating risks in multinational operations.
Key Topics:
Local and international regulatory compliance obligations
Audits, inspections, and documentation reviews
Risk assessment and identification of exposure areas
Penalties and consequences for non-compliance
Integration with corporate governance and internal controls
Best practices for monitoring and reporting
Practical Focus:
Exercise: Conduct a transfer pricing risk assessment for a multinational entity.

Module 5: Intellectual Property and Transfer Pricing
Overview:
Covers the special considerations for transfer pricing of intangible assets.
Key Topics:
Valuation of intellectual property (IP) and intangibles
Licensing, royalties, and cost-sharing arrangements
Arm’s length pricing for IP transactions
Documentation and reporting requirements for intangibles
Dispute resolution involving IP and transfer pricing
Case studies of IP-related transfer pricing controversies
Practical Focus:
Workshop: Prepare documentation and pricing analysis for an IP licensing agreement.

Module 6: Financing and Intra-Group Services
Overview:
Focuses on transfer pricing for intra-group financing and service transactions.
Key Topics:
Intra-group loans, guarantees, and financial services
Arm’s length interest rates and terms
Shared service arrangements and cost allocation
Compliance and documentation requirements
Audit strategies and dispute management
Case studies of intra-group service arrangements
Practical Focus:
Exercise: Draft a transfer pricing analysis for intra-group financing arrangements.

Module 7: Dispute Resolution and Advance Pricing Agreements (APAs)
Overview:
Examines mechanisms for resolving transfer pricing disputes and obtaining certainty.
Key Topics:
Transfer pricing audits and controversies
Alternative dispute resolution mechanisms
Advance Pricing Agreements (APAs) and mutual agreement procedures (MAPs)
Negotiating and documenting APAs
Litigation and administrative remedies
Case studies of successful dispute resolution strategies
Practical Focus:
Simulation: Prepare an APA application and negotiation strategy for a multinational transaction.

Module 8: Emerging Trends in Transfer Pricing and International Tax
Overview:
Covers current developments and global initiatives affecting transfer pricing.
Key Topics:
OECD BEPS (Base Erosion and Profit Shifting) actions and implementation
Digital economy and transfer pricing challenges
Global minimum tax (Pillar Two) and taxation of multinational enterprises
ESG and sustainability considerations in international taxation
Impact of regulatory changes on compliance and planning
Future-proofing transfer pricing strategies
Practical Focus:
Case study: Analyze the impact of BEPS and global minimum tax on a multinational enterprise.

Module 9: Corporate Governance and Internal Controls
Overview:
Examines governance structures and internal controls for transfer pricing compliance.
Key Topics:
Board responsibilities and oversight for transfer pricing policies
Internal control frameworks and audit mechanisms
Documentation, reporting, and monitoring obligations
Integrating tax planning with corporate strategy
Ethical and governance considerations in international taxation
Lessons from transfer pricing failures
Practical Focus:
Workshop: Develop an internal control framework for managing transfer pricing compliance.

Module 10: Capstone Project – Strategic Transfer Pricing Advisory
Overview:
Applies all knowledge gained in a practical, strategic advisory context.
Key Topics:
Comprehensive assessment of a multinational enterprise’s transfer pricing
Structuring transactions, policies, and documentation for compliance
Risk management and dispute resolution planning
Drafting advisory reports and recommendations
Presentation and peer review of strategic transfer pricing solutions
Lessons learned and global best practices
Practical Focus:
Capstone Project: Develop a complete transfer pricing strategy for a multinational entity, including documentation, compliance measures, and dispute resolution mechanisms