Handling Complex Transfer Pricing Cases - Strategies,
Litigation, and Dispute Resolution
29 June – 07 July 2026
Sandown Sandton
Johannesburg South Africa
Register Now! Limited Seats Available!
R 24,999.00 Per Delegate
Course overview:
In today’s globalized economy, multinational enterprises (MNEs) operate across multiple tax jurisdictions, creating complex intercompany transactions that must comply with transfer pricing (TP) regulations. As tax authorities worldwide intensify scrutiny on cross-border pricing practices, disputes over the determination of arm’s-length prices have become increasingly common—and often culminate in sophisticated litigation processes.
This 10-day intensive program on Transfer Pricing Strategies with a Focus on Litigation Techniques for Handling Complex Cases in Court provides a comprehensive understanding of both the technical and legal dimensions of transfer pricing. It is designed for professionals involved in tax administration, corporate taxation, legal practice, and financial management who need to navigate the intricate interface between international taxation and dispute resolution.
Course Objectives:
• Comprehend the principles and methods of transfer pricing and their practical applications.
• Identify risk areas and compliance requirements in TP audits and documentation.
• Analyze and manage disputes using legal and strategic approaches.
• Prepare, present, and defend transfer pricing cases effectively in court or before tax tribunals.
• Engage in negotiations and alternative dispute resolution (ADR) mechanisms.
• Apply lessons from key international TP litigation precedents to real-world cases.
Who Should Attend?
• Tax auditors, TP specialists, and investigators
• Legal practitioners and corporate counsel
• Accountants and financial controllers of multinational entities
• Revenue authority officers involved in transfer pricing audits
• Policy analysts and tax advisors
• Compliance and regulatory officers
Course Outline:
Fundamentals of Transfer Pricing
• The role of transfer pricing in international taxation
• The Arm’s-Length Principle: concept, evolution, and application
• Overview of OECD and UN TP frameworks
• Key transfer pricing methods: CUP, Resale Price, Cost Plus, TNMM, Profit Split
• Functional, asset, and risk analysis (FAR) in TP studies
Transfer Pricing Documentation and Compliance
• Local file, master file, and country-by-country reporting (CbCR)
• Best practices in documentation and record-keeping
• Developing robust benchmarking studies
• Managing data and comparability challenges
• Regulatory compliance and penalty frameworks
Risk Identification and Transfer Pricing Audit Process
• Recognizing potential TP risk areas in multinational operations
• Tax authority audit procedures and information requests
• Handling queries and responding to assessments
• Managing taxpayer-authority relationships and communications
• Use of technology and data analytics in TP risk management
Dispute Triggers and Case Preparation
• Common causes of TP disputes and controversy management
• Assessments, adjustments, and objections procedures
• Burden of proof and evidentiary standards
• Preparing TP defense files and rebuttals
• Developing persuasive case theories and arguments
Litigation Framework and Legal Procedures
• National and international legal frameworks governing TP disputes
• The litigation process: from assessment to appeal
• Drafting pleadings, affidavits, and supporting documents
• Expert witnesses: role, selection, and report preparation
• Effective presentation of evidence before tax tribunals or courts
Litigation Techniques and Courtroom Strategy
• Cross-examination and witness handling skills
• Techniques for oral arguments and courtroom advocacy
• Managing expert and technical evidence
• Strategic communication and persuasion in court
• Review of landmark court decisions and judicial reasoning
Alternative Dispute Resolution (ADR) and Global Practices
• Mutual Agreement Procedures (MAPs) and Advance Pricing Agreements (APAs)
• Arbitration and mediation as alternatives to litigation
• Comparative analysis of dispute resolution approaches across jurisdictions
• Negotiation and settlement strategies before litigation
• Managing relationships with tax authorities and international bodies
Practical Case Studies and Simulations
• Step-by-step walkthrough of actual TP litigation cases
• Analysis: identifying strengths and weaknesses in case positions
• Role-playing sessions: taxpayer vs. revenue authority
• Mock tribunal simulation – argument presentation and judgment delivery
• Lessons learned and post-litigation evaluation techniques
Strategic Review and Future Trends
• Final review, group discussion, and certificate presentation
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
