Advanced Transfer Pricing Strategies -A Practical
Guide to Optimizing Your Global Taxation
Dates to be Advised
Register Now! Limited Seats Available!
R19, 999.00 Per Delegate
Overview
As multinational enterprises (MNEs) continue to expand globally, cross-border transactions between associated entities have become increasingly complex and scrutinized by tax authorities. Transfer Pricing (TP) has emerged as one of the most critical issues in international taxation, especially in light of the OECD’s Base Erosion and Profit Shifting (BEPS) initiatives and the global implementation of Pillar One and Pillar Two tax reforms.
This intensive course on Advanced Transfer Pricing Strategies is designed to equip tax professionals and regulatory officers with practical tools and up-to-date insights into managing and optimizing global taxation through strategic transfer pricing. Participants will delve into complex TP scenarios involving intangibles, intercompany financing, cost-sharing arrangements, and digital economy transactions. Through real-world case studies, hands-on simulations, and expert guidance, the course bridges technical knowledge and strategic application to support compliant and tax-efficient global business operations.
Program Objectives:
By the end of this course, participants will be able to:
• Understand advanced principles of transfer pricing (TP) and its impact on global tax structures
• Apply OECD guidelines and BEPS (Base Erosion and Profit Shifting) action items effectively
• Design and implement tax-efficient TP models
• Manage risk and compliance through documentation and dispute resolution
• Utilize data and digital tools for TP planning and audit defense
Who Should Attend:
- Tax Managers and Tax Directors
- Finance Managers and Controllers
- CFOs and Financial Analysts
- Legal and Compliance Officers
- Heads of International Business Units
- Tax Authority Officers (especially those involved in audit, TP, or policy units)
- Revenue and Customs Inspectors
- Economic Policy Advisors
- Transfer Pricing and BEPS Specialists
- Transfer Pricing Consultants
- Accountants and Auditors
- Legal and Tax Advisors
- International Tax Consultants
Program Outline:
Day 1: Fundamentals and International Framework
1. Recap of Basic Transfer Pricing Principles
o Arm’s Length Principle
o Associated Enterprises
o Comparability Analysis
2. Global Regulatory Framework
o OECD Guidelines
o UN Practical Manual
o Local Laws vs. International Practice
o Role of the Inclusive Framework
3. Introduction to BEPS and the 15 Action Items
o Focus on Action 8–10 (Aligning TP Outcomes with Value Creation)
o Country-by-Country Reporting (CbCR)
Day 2: Strategic Transfer Pricing Models
1. Global Value Chains and TP Planning
o Identifying Key Value Drivers
o Supply Chain Restructuring
2. Advanced TP Methods
o Profit Split Method
o Transactional Net Margin Method (TNMM)
o Residual Profit Allocation
o Valuation Techniques for Intangibles
3. TP for Intangible Assets
o IP Migration
o Cost-Sharing Arrangements
o DEMPE Function Analysis (Development, Enhancement, Maintenance, Protection, Exploitation)
Day 3: Tax Optimization and Risk Management
1. TP Risk Identification and Mitigation
o TP Risk Indicators
o Proactive vs. Reactive TP Management
2. Intercompany Financing and TP
o Loan Pricing
o Financial Guarantees
o Treasury Function TP
3. TP in the Digital Economy
o Digital Services and Data-Driven Models
o Global Minimum Tax and Pillar One & Two
o Challenges in Valuing Data and Algorithms
Day 4: Compliance, Documentation & Dispute Resolution
1. TP Documentation and Reporting
o Master File, Local File, CbCR
o Benchmarking Studies
o Documentation Best Practices
2. TP Audits and Controversy Management
o Audit Risk Factors
o Managing Tax Authority Interactions
o Penalties and Interest
3. Dispute Resolution Mechanisms
o Mutual Agreement Procedure (MAP)
o Advance Pricing Agreements (APAs)
o Arbitration and Mediation
Day 5: Practical Case Studies & Strategic Planning
1. Real-World TP Case Studies
o Industry-Specific Scenarios (e.g., Pharma, Tech, Mining)
o Local and Global Jurisdiction Conflicts
2. Designing a Transfer Pricing Strategy
o Aligning TP with Corporate Strategy
o Integrating TP with ERP and Tax Technology Systems
3. Interactive Workshop
o Group Simulation: Develop a Global TP Policy
o Presentations and Feedback
o Q&A with Experts
End of the workshop
IN HOUSE AND ONLINE TRAINING
While both In-House and Online training can present with cost-effectiveness and time-efficacy, there are some very specific differences between in-house courses and those based online.
The demand for additional courses by individuals or groups of people is increasing. Still, it depends entirely on the preferences of a person what type of training he or she wants to receive. Online courses and in-house training carry some similarities but they are considered to exhibit some very pivotal differences too. Despite that, both types of learning can be really beneficial for attendees.
For Registration and other Training arrangements,
contact us on the detail below.
SOUTH AFRICA : +27 11 057 6001
TANZANIA Cell: +255 769 688 544
WhatsApp +27 79 574 0389
info@bmktraining.co.za / www.bmktraining.com
