Transfer Pricing Masterclass

Day one: Designing and assessing the TP framework

Setting the scene
The TP lifecycle and the role of documentation
What it means to be in control of your TP position
Aligning TP positions with organisational risk tolerance 

The changing reference framework
OECD vs UN approaches
Geopolitical forces shaping TP
Emerging and alternative TP models

TP design
TP methods and business models
Value creation and benchmarking 

Intercompany services
HQ management and group support services
Low- and high-value-adding services
Intermediate financial services and intangibles 

Threshold for taxable presence
Permanent establishments
Geographically dispersed management
Dependent agent considerations

Associated enterprises
Criteria for association
Joint ventures and TP implications 

Day two: Implementing, managing, and defending TP

Implementation and price setting
From price testing to price setting
Goal-seeking and price adjustments
Transactional design

Financial transactions
Debt funding and guarantee fees
Cash pooling
Captive insurance

Business restructuring
Purpose and scope of regulations
BEPS and post-BEPS considerations

Dispute resolution
Primary, corresponding, and secondary adjustments
Available dispute resolution instruments
Effectiveness in practice

Compliance
Purpose of TP compliance
Data quality and consistency
Preparing three-tiered documentation

Pillar Two and transfer pricing
High-level overview of Pillar Two rules
Interaction between Pillar Two and TP