Objectives

Upon completion of this course, participants will be able to:

• Identify and analyze the core principles of international tax law and double taxation treaties.
• Understand the role and application of the OECD Model Tax Convention and BEPS initiatives.
• Define and apply the arm's length principle for various intercompany transactions.
• Select and justify appropriate transfer pricing methods (e.g., CUP, Resale Price, Cost Plus, TNMM).
• Develop comprehensive transfer pricing documentation that meets local and international standards.
• Manage and resolve international tax audits and disputes, including Advance Pricing Agreements (APAs).
• Evaluate the tax implications of global business restructuring and intangible property transfers.
• Implement effective tax planning strategies while ensuring adherence to compliance and substance requirements.

Target Audience

• Tax Directors, Managers, and Specialists
• Financial Controllers and Chief Financial Officers (CFOs)
• Internal Auditors and Compliance Officers
• Legal Counsel specializing in corporate or international law
• Consultants providing tax and business advisory services
• Senior Accountants and Finance Professionals in multinational companies
• Government officials and tax authority employees

• Case studies and real-world transfer pricing disputes analysis
• Interactive workshops on developing functional analysis reports
• Group activities simulating transfer pricing policy selection and justification
• Individual exercises on applying transfer pricing methods and calculations
• Expert-led discussions on recent BEPS developments and policy trends
• Role-playing exercises for audit defense and negotiation strategies
• Use of specialized transfer pricing software/tools demonstrations

Unit 1: Foundations of International Taxation

• Overview of international tax jurisdiction and nexus rules
• Understanding residency vs. source taxation principles
• The role of Double Taxation Treaties (DTTs) and tax holidays
• Introduction to the OECD and UN Model Tax Conventions
• Tax implications of Permanent Establishments (PE)
• Tax havens and anti-avoidance legislation

• Origins and aims of the BEPS project (BEPS 1.0 and 2.0)
• Action Plan items and their impact on global tax law
• Country-by-Country Reporting (CbCR) requirements and utilization
• The concept of global minimum tax (Pillar Two)
• Treaty abuse and the Principal Purpose Test (PPT)
• Digital economy taxation challenges (Pillar One)

Unit 2: The Arm's Length Principle and Transfer Pricing Methods

• The legislative and regulatory basis for transfer pricing
• Identifying related party transactions and intercompany dealings
• Functional Analysis: identifying functions, assets, and risks (FAR)
• Selecting the tested party in transfer pricing analysis
• Interpreting the OECD Transfer Pricing Guidelines
• Risk assumption, control over risk, and contractual arrangements

• Traditional Transaction Methods: CUP, Resale Price, and Cost Plus
• Transactional Profit Methods: TNMM and Profit Split
• Step-by-step guidance on selecting the Most Appropriate Method
• Practical application of benchmarking studies and data sources
• Adjustments for material differences in comparability analysis
• Case studies on method selection for different types of transactions

Unit 3: Transfer Pricing for Specific Transactions

• Low value-adding vs. high value-adding services distinction
• Determining service benefits and charge-out mechanisms
• Application of simplified approaches and safe harbors
• Allocation keys and documentation requirements for services
• The concept of "stewardship" activities
• Cost contribution arrangements (CCAs) for shared services

• Defining and classifying intangible property (IP) for tax purposes
• Transfer pricing of hard-to-value intangibles (HTVIs)
• DEMPE (Development, Enhancement, Maintenance, Protection, Exploitation) concept
• Pricing intercompany loans, guarantees, and cash pooling
• Thin capitalization rules and interest deductibility limitations
• Royalty rates and IP migration structures

Unit 4: Compliance, Documentation, and Controversy

• Structure and required content of the Master File
• Specific content requirements for the Local File
• Strategic approach to preparing contemporaneous documentation
• Penalties for insufficient or late documentation
• Local country variations in documentation requirements
• Best practices for data collection and retention

• Preparing for and managing transfer pricing audits effectively
• The Mutual Agreement Procedure (MAP) for resolving double taxation
• Understanding Advance Pricing Agreements (APAs) and their benefits
• Strategies for presenting and defending transfer pricing policies
• Litigation trends and key court cases in transfer pricing
• Tax certainty mechanisms and proactive compliance

Unit 5: Advanced International Tax Topics

• Identifying CFCs and calculating attributed income
• The purpose and impact of CFC legislation globally
• Exemptions and thresholds in various jurisdictions
• Interaction of CFC rules with DTTs

• Understanding the mechanics of withholding tax on dividends, interest, and royalties
• Application of reduced withholding tax rates under DTTs
• International aspects of Value Added Tax (VAT) and Goods and Services Tax (GST)
• Cross-border digital services and indirect tax compliance