Taxation and Transfer Pricing Strategies: Optimizing Global Tax Efficiency

Module 1: Foundations of International Taxation

Principles of international taxation

Double taxation and tax treaties

The role of global tax policy in competitiveness

Module 2: Introduction to Transfer Pricing

Transfer pricing concepts and importance

OECD Transfer Pricing Guidelines

Arm’s Length Principle and its application

Module 3: Transfer Pricing Methods and Applications

Comparable Uncontrolled Price (CUP) method

Resale Price and Cost-Plus methods

Transactional Net Margin Method (TNMM) and Profit Split Method

Selecting the most appropriate method

Module 4: Regulatory Compliance and Documentation

Local file, master file, and country-by-country reporting (CbCR)

Documentation requirements under OECD BEPS Action 13

Managing compliance risks across jurisdictions

Module 5: Managing Cross-Border Transactions

Intercompany financing, royalties, and intangibles

Supply chain structuring for tax efficiency

Pricing of intra-group services

Module 6: Tax Risk Management and Dispute Resolution

Identifying and mitigating transfer pricing risks

Audit readiness and managing tax authority challenges

Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs)

Module 7: Optimizing Global Tax Efficiency

Tax-efficient structuring of multinational operations

Holding companies, IP structures, and financing strategies

Balancing compliance and tax planning

Module 8: Emerging Issues in Transfer Pricing

Digital economy taxation challenges

Transfer pricing in developing countries

ESG and sustainability considerations in global tax policy

Module 9: Case Studies and Practical Applications

Real-world examples of transfer pricing disputes and solutions

Best practices in implementing global tax strategies

Group exercises in transfer pricing analysis and policy design