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Fundamentals of 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 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.




Tax, accounting, or legal professionals working in-house or in an advisory firm, who need a broad, introductory understanding of transfer pricing or who want to lay the foundations for further learning about transfer pricing.

The course assumes no prior knowledge of transfer pricing, but participants will find it helpful to have an understanding of:

  • Accounting, including the contents of profit and loss accounts and balance sheets
  • How companies are taxed
  • Economic concepts affecting businesses, such as supply and demand and opportunity costs

Course Content


  • What is transfer pricing and why does it matter?
  • What do transfer pricing rules typically require companies to do?
  • The arm’s-length principle and how to apply it
  • Comparability
  • The five transfer pricing methods, with practical examples
  • Application to sales of tangible goods
  • Application to intragroup services
  • Application to intellectual property and other intangible assets
  • BEPS

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