Principles of International Transfer Pricing

Introduction

The Principles of International Transfer Pricing Course provides a comprehensive understanding of how multinational enterprises determine fair pricing for intercompany transactions in today’s globalized tax environment. With tax authorities around the world tightening regulations, mastering transfer pricing principles has become essential for ensuring compliance, reducing tax risk, and maintaining transparency. This training course helps professionals develop a solid foundation in international transfer pricing frameworks and their application across diverse industries. Participants will explore the core methodologies—including the arm’s length principle, cost-plus method, transactional net margin method (TNMM), and profit split method (PSM)—that underpin fair market value assessments between related entities. The Principles of International Transfer Pricing Training also examines the relationship between transfer pricing and broader areas such as taxation, accounting, and finance, giving participants an integrated understanding of how these domains intersect. By attending this course, participants will gain practical insights into global standards, OECD guidelines, and documentation requirements. Real-world examples and case discussions will enable learners to navigate complex cross-border pricing scenarios, mitigate compliance risks, and enhance corporate tax planning strategies that align with international best practices.

Objectives

This Principles of International Transfer Pricing Training is designed to enhance participants’ technical and analytical competence in managing transfer pricing policies effectively within their organizations.

By the end of this training course, participants will be able to:

• Strengthen their understanding of international transfer pricing concepts and methods
• Explain the importance and practical application of the arm’s length principle
• Evaluate the stages and components of a complete transfer pricing analysis
• Analyze domestic tax base erosion and profit shifting (BEPS) issues
• Understand the legal and regulatory framework governing transfer pricing
• Recognize current global developments, OECD guidance, and emerging trends

Training Methodology

This Principles of International Transfer Pricing Training adopts a highly interactive and practical learning approach to maximize engagement and comprehension. Participants will benefit from a combination of instructor-led sessions, case studies, and collaborative exercises that translate theoretical concepts into actionable expertise. The course integrates real-world scenarios reflecting international tax environments and OECD transfer pricing guidelines. Group discussions and exercises will encourage participants to apply learned methodologies to complex, cross-border pricing challenges faced by multinational corporations.

Key learning methods include:

• Expert-facilitated presentations and technical briefings
• Group case studies aligned with OECD and UN models
• Interactive exercises on pricing adjustments and compliance documentation
• Practical examples illustrating intra-group transaction management
• Engaging video analysis to reinforce key principles

Through these learning activities, participants will gain the confidence to apply compliant, efficient, and strategic transfer pricing solutions within their organizations.

Who Should Attend?

The Principles of International Transfer Pricing Course is tailored for professionals involved in tax strategy, corporate finance, and compliance who seek to deepen their understanding of international pricing policies. It is particularly beneficial for:

• Financial accounting and reporting professionals
• Cost and management accounting staff
• Finance and budget managers
• Commercial and operations managers
• Capital investment and project analysts
• M&A and investment evaluation teams
• Risk and compliance managers

Course Outline

Day 1:  Introduction to Transfer Pricing

• Separate-entity approach

• What is transfer pricing?

• The significance of intra-group relations

• The importance of transfer pricing to states

• The importance of transfer pricing to MNE Groups

Day 2:  The Legal Framework

• The international tax environment

• The arm’s length principle

• The alternative to the arm’s length principle: a global formulary apportionment

• The features of domestic transfer pricing regimes

• The importance of tax treaties (OECD and UN Models- Art. 9 and 25)

• The importance of the OECD Transfer Pricing Guidelines

Day 3:   Transfer Pricing Methods 

• The Comparable uncontrolled price (CUP) method

• The Resale price method (RPM)

• The Cost-plus method

• The Transactional net margin method (TNMM)

• The Profit split method (PSM)

• The Commodity rule

Day 4:  Transfer Pricing Adjustments

• Compensating adjustments

•  Primary adjustments

•  Corresponding adjustments

•  Secondary adjustments

•  Repatriation  

Day 5:  Transfer Pricing Documentation

• Purpose of transfer pricing documentation

• Domestic transfer pricing documentation rules

• OECD Guidance (OECD Transfer Pricing Guidelines: Chapter V)

• Compliance issues

• United Nations Guidance

• Case studies and examples