Transfer Pricing

Recognise transfer pricing issues in cross-border groups and understand which framework to turn to. This course introduces the arm’s length principle and OECD Guidelines, functional and comparability analysis, method selection, documentation and audit readiness.

Explore common issues in intercompany services, intangibles, financing and distribution, alongside Pillar One Amount B for baseline distributors and the roles of APAs and MAPs. The focus is awareness and recognition: spotting issues, understanding the available frameworks and knowing when to involve a transfer pricing specialist. It does not teach full numerical transfer pricing calculations or specialist documentation drafting.

Course format and CPD

This course provides 2 units of CPD. Scored lesson quizzes build recognition across the key topics, and a cumulative final assessment brings the learning together.

Course outline

1. Transfer Pricing
2. The Arm's Length Principle and the OECD Guidelines
3. Functional and Comparability Analysis
4. Transfer Pricing Methods and Method Selection
5. Intercompany Services, Intangibles, Financing and Distribution
6. Documentation, Benchmarking and Audit Readiness
7. Pillar One Amount B for Baseline Distribution
8. Dispute Prevention and Resolution: APAs, MAPs and Tax Authority Challenges
9. Transfer Pricing Final Assessment
10. Recap and Next Steps

Downloadable course companion

Download the fillable and printable worksheet to record transaction facts, evidence gaps and questions for a transfer pricing specialist. This supplementary companion is separate from the LMS lessons and assessment and does not add CPD credits.

Course companion worksheet (PDF)