Transfer Pricing Strategies

07 – 11 April 2025
Sandton Centre Johannesburg South Africa

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R19, 999.00 Per Delegate

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Course overview:

Transfer Pricing is arguably the most important tax issues faced by international companies and tax administrations. It also remains a leading and challenging issue for tax and financial specialists of international companies and tax authorities.

This course explores the transfer pricing issues confronting a multinational group that operates in a number of jurisdictions around the globe. Owing to the OECD BEPS statements on the topic of transfer pricing, the curiosity in transfer pricing has risen even more.

The crucial new terms in the field of international taxation are ‘substance’ and ‘transparency’, and these stipulations are relevant to transfer pricing as well. This program has been particularly customised for the functional needs of tax, finance and transfer pricing experts working with the tax authorities and in a variety of trade and service sectors.

What areas will this “Transfer Pricing in Taxation” course cover?  The course aims to expand your skills and knowledge in Transfer Pricing which, in turn, will enhance your employability. It will also provide a comprehensive and real-world understanding of Transfer Pricing and scrutinise the latest policy progress and tax treatment of complex Transfer Pricing relations

Course Objectives:

Upon completing this course successfully, participants will be able to:

  • Gain a comprehensive grounding in all aspects of transfer pricing
  • Understand the importance and principles of international transfer pricing in their professions.
  • Tackle the significant issues within different sectors, extracting and discussing vital points to ensure you gain a thorough understanding of the topics
  • Evaluate transactions of international cross border exchange of good, services and intangibles Identify the significance of a unified international political approach through the BEPS project.
  • Appreciate the focus of the government on transfer pricing in the Middle East and North Africa.
  • Proactively comply and implement processes and policies with future anticipated regulations.

Who Should Attend?

This course would be suitable for:

  • Transfer pricing advisors
  • Accountants
  • Tax inspectors
  • Tax auditors
  • Legal counsel and lawyers
  • General tax practitioners
  • Tax practitioners in advisory firms
  • Beginners in tax commercial and trade industries
  • Government officials from revenue authorities and finance ministries
  • In-house tax directors/managers
  • Tax regulation bodies
  • Financial analysts

Course Outline:

INTRODUCTION TO TRANSFER PRICING

  • The importance of transfer pricing
  • Separate-entity approach
  • What is transfer pricing?
  • The significance of intra-group relations
  • Groups and tax administrations
  • Transfer pricing documentation:
    • Content
    • Purpose
    • Guidelines
    • Master and local file
    • Country-by-country reporting
  • Transfer pricing dispute avoidance and resolution.
  • Procedures for avoidance and resolution of transfer pricing disagreements

TRANSFER PRICING METHODS

    • Comparable Uncontrolled Price (CUP) method
    • Resale Price Method (RPM)
    • Cost Plus Method (CPM)
    • Transactional Net Margin Method (TNMM)
    • Profit Split Method (PSM)
    • Best method selection and documentation requirements

TRANSFER PRICING DOCUMENTATION

    • Documentation requirements under various jurisdictions
    • Documentation formats and content
    • Penalty provisions for non-compliance

TRANSFER PRICING AUDITS AND DISPUTE RESOLUTION

    • Conducting transfer pricing audits
    • Dispute resolution mechanisms
    • Mutual Agreement Procedure (MAP)
    • Advance Pricing Agreements (APAs)
    • Competent Authority Proceedings

COMPARABILITY

  • Transfer pricing impact over the business:
  • Specific issues for the transfer pricing of goods and services, intangibles and financing
  • Compliance, implementation and monitoring of risk management
  • Ongoing costs in maintaining a robust contemporaneous environment

COOKIES CASE INTEGRATING PRACTICE

  • Integrated practice
  • Profit Split Method
  • Administrative Aspects of Transfer Pricing Control
  • Transfer pricing from Brazilian legislation

 

ADVANCE PRICING AGREEMENTS

  • Mutual agreement procedure
  • Arbitration

CONTROVERSIES

TRANSFER PRICING POST-BEPS

  • Workshop Transfer Pricing and Digitisation
  • OECD Discussion on Transfer Pricing Features of Financial Transactions
  • New OECD Project to Revise the Guidance
  • Chapter VII of the OECD TP Guidelines
  • Special Considerations for Intra-Group Services

CASE STUDY PART 1 – INTRA-GROUP SERVICES

  • Management service fees
  • Identification of chargeable services
  • Service charge computation

CASE STUDY PART 2 – MANUFACTURING AND DISTRIBUTION ACTIVITIES

  • Risk analysis
  • Functional analysis
  • Marketing intangibles
  • Methodology selection
  • Other pricing considerations

CASE STUDY PART 3 – FINANCIAL ACTIVITIES

  • Risk analysis
  • Loan pricing policy
  • Guarantee fees

End of the workshop

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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