Fundamentals of transfer pricing

A practical, hands-on introduction to the most significant international tax risk facing multinational businesses – transfer pricing. The course covers the technical foundations that you need to know and how to apply them to real life scenarios. It will help you to identify and prioritise transfer pricing risks, develop a transfer pricing policy and prepare appropriate documentation. Case studies and practical examples are used throughout the course, drawing on the wealth of experience of the presenters. This course is also an ideal introduction to the topic if you are planning to take the new transfer pricing option in paper 3 of the Advanced Diploma in International Tax.

Learn the basics of transfer pricing theory and legislation
Be able to identify, analyse and prioritise transfer pricing risks;
Understand the key steps required to develop a transfer pricing policy and support it using documentation and other methods;
Learn how to conduct a functional analysis to identify functions performed, risks assumed and assets employed in respect of intra-group transactions, and characterise the entities involved;
Learn how to select and apply the most appropriate transfer pricing method based on the nature of the intra-group transactions, information available and interpretation of transfer pricing theory;
Understand the key issues to consider in conducting economic analysis to support intra-group transactions; and
Be better prepared to defend transfer pricing policies and positions.
Introduction to advance agreements and dispute resolution

Day 1

Overview of UK and other countries' transfer pricing legislation, OECD Transfer Pricing Guidelines and relevant caselaw
Interaction with tax treaties and permanent establishment concepts
Transfer Pricing project planning and strategy
Fact gathering and functional analysis
Entity characterisation
Identifying material risks
Selection of the most appropriate method

Day 2

Economic analysis: Comparability factors; Benchmarking studies; Comparable company searches
Key intra-group transactions including: Products; Services; Cost Contribution Arrangements; Intellectual Property; Financing transactions; Documentation

Tutors: Ken Almand, Baker Tilly UK

Level: Basic

Dates:

23-24 April 2012
15-16 October 2012

Venue: London

Book online or alternatively, book by phone on +44 (0)20 7847 5804

Cost:

Bloomberg BNA Members: £1,025
Non Members: £1,300

Early booking discounts available so book now

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