Course Highlights
  • Transfer Pricing
  • Fundamental sources
  • What is "multinational enterprise"
  • What are "intragroup transactions"
  • What is the "arm's length principle"
  • What companies are "associated enterprises"
  • Which transactions are controlled
  • Comparability and five OECD comparability factors
  • Why we need functional analysis
  • What is entity characterization
  • Risk analysis framework
  • Transfer pricing methods
  • Transfer pricing documentation
Curriculum

1 Topic
Introduction to the course

7 Topics
Introduction and the Context
Multinational Enterprises (MNEs)
Intragroup Transactions
What is Transfer Pricing?
The Arm's Length Principle
Fundamental Sources of Transfer Pricing Rules
Module 1 quiz

4 Topics
Associated Enterprises
Controlled Transactions
Comparability
Module 2 quiz

7 Topics
Introduction to Functional Analysis
Why Functions Assets and Risks (FARs) are Important?
Functional Analysis Example - Simplified
OECD Risk Analysis
Entity Characterization
Functional Analysis and Transfer Pricing Methods
Module 3 quiz

8 Topics
Transfer Pricing Methods Overview
Comparable Uncontrolled Price Method (CUP)
Resale Price Method (RPM)
Cost Plus Method (CPM)
Transactional Net Margin Method (TNMM)
Transactional Profit Split Method (PSM)
Comparability Analysis in General
Module 4 quiz

5 Topics
Transfer Pricing Compliance in General
Transfer Pricing Documentation: Local File Master File CbCR
Transfer Pricing Audits
Module 5 quiz
What's next?

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Transfer Pricing Fundamentals

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