This fundamentals of transfer pricing course gives a comprehensive overview of tax, accounting, or legal professionals working in-house or in an advisory firm, for those who need a broad, introductory understanding of transfer pricing or who want to lay the foundations for further learning about transfer pricing.
Over the last two decades, transfer pricing rules have proliferated to the extent that there are few countries of any size that have not introduced transfer pricing legislation. It has become a key issue for in-house tax departments, tax advisers, and tax authorities. Journalists, campaigners and politicians have highlighted perceived abuses by companies. The scope for adverse PR and significant disputes with tax authorities has elevated transfer pricing to an issue of concern to most boards.
Most multinational businesses of any significant size need to devote at least some effort to compliance with transfer pricing rules and optimising where possible; for many multinationals it is one of their key areas of focus in relation to tax. This course aims to provide a basic grounding for professionals in the early stages of learning about transfer pricing. Discussion and interaction will be encouraged.
The course includes a review of the latest developments, which currently include:
- The OECD’s likely introduction of new rules under which multinationals can have taxable presence in market jurisdictions. This is likely to entail new rules for determining profits that may override the arm’s length test.
- The EU’s introduction of DAC 6, under which multinationals and advisers will have mandatory obligations to file disclosures of transfer pricing arrangements that meet certain criteria.
The course is not specific to any particular country; it is based on international norms. Nor is it specific to any industry; it covers transactions that arise in almost all industries.