Transfer Pricing Tax Course Diploma Certification Taxation Certificate


Program Outline

The Diploma has been divided into four modules that discusses:

Module A:

    • Introduction
    • Management Accounting Origins
    • Multinational Enterprises
    • Taxation Context
    • The Need for Transfer Pricing Taxation Rules
    • The OECD
    • The OECD Transfer Pricing Guidelines
    • OECD Model Double Tax Convention (DTC)
    • Other Model Double Tax Conventions
    • Introduction 
    • Protecting Individual tax Bases
    • Arm’s Length Principle
    • OECD Model Article 9
    • Article 9 Paragraph 1
    • Article 9 Paragraph 2
    • Difficulties in Applying the Arm’s Length Principle
    • Alternatives to the Arm’s Length Principle
    • Introduction
    • The OECD Model DTC and the Definition of Associated Enterprises
    • State Practice and the Associated Enterprises Definition
    • Conclusion
    • Introduction
    • The OECD TPG and Comparability
    • The Five Comparability Factors
    • Losses
    • Performing a Comparability Analysis
    • Typical Process
    • Comparable Uncontrolled Transactions
    • External Comparables and Sources of Information
    • Selecting or Rejecting Potential Comparables
    • Comparability Adjustments
    • Arm’s Length Range
    • Timing Issues in Comparability

Module B:

    • Introduction
    • Comparable Uncontrolled Price (CUP) Method
    • Resale Price Method (RPM)
    • Cost Plus Method (CPM)
    • Transactional Profit Methods
    • Examples of Functional Profiles and Links to Pricing Methodologies
    • Functional Analysis
    • Introduction
    • Goals to Functional Analysis
    • Analysis of Functions, Assets and Risks
    • Risk
    • Summarising the Functional Analysis
    • Choice of Tested Party
    • Entity Characterisation – Comparison of Simple and Complex Entities
    • Sales Functions
    • Manufacturing Entities
    • Support Service Activities
    • More Complex or Entrepreneurial Entities

Module C:

    • Introduction
    • Determining whether a Service has been Rendered
    • Determining an Arm’s Length Charge
    • Transfer Pricing Method
    • Low Value-adding Intra group Services
    • Cost Contribution Arrangements
    • Introduction
    • Loans
    • Thin Capitalisation
    • Interest-free Loans
    • Guarantee Fees
    • Specific Transactions: Intangible Property
    • Introduction
    • The Life Cycle of Intangibles
    • Development of Intangibles
    • Exploiting Intangibles: Principal Structure v. Licensing Out
    • OECD TPG and Intangibles
    • Valuation of Intangibles
    • Hard to Value Intangibles (HTVI)
    • Introduction
    • The Rationale for Restructuring and the Role of Tax
    • Typical Models Applied During Restructuring
    • The OECD Approach
    • Tax Authorities’ Response to Business Restructuring
    • Conclusion
    • Introduction to Permanent Establishments
    • Physical Presence PE
    • Exclusions from Definition of a PE
    • Anti-fragmentation
    • Agency PE
    • Position of Subsidiary
    • Related Party
    • Services PE
    • E-Commerce Issues
    • The Multilateral Instrument (MLI)
    • Attribution of Profits
    • Business Profits (Article 7 OECD Model Treaty)
    • Recent Updates to the Model Convention
    • Practical Application of the Transfer Pricing Process
    • Attribution of Profit in Excess of the Total Profit of the Enterprise
    • Comparison of the Article 7 OECD Approach to Article 9
    • Double Taxation Relief

Module D:

    • Introduction
    • Corresponding Adjustments
    • The Mutual Agreement Procedure
    • The Tax Treaty Arbitration Procedure
    • Introduction
    • Circumstances where Non-recognition may Apply
    • Introduction
    • What is an APA?
    • Duration of an APA?
    • Introduction
    • Why is Documentation Important?
    • The OECD Guidelines on Transfer Pricing Compliance
    • Unilateral or Multilateral Documentation?
    • Safe Harbours

Globalisation and economic growth have driven transfer pricing to emerge as one of the most critical issues in International tax. To address the need of formal training in transfer pricing, which need is felt by students, practitioners, corporations, lawyers, economists, judiciary and the Government alike, The Tax Guild is pleased to offer the Diploma in Transfer Pricing in partnership with Tolley’s and ATT (Association of Taxation Technicians). This ATT Diploma in Transfer Pricing, in partnership with Tolley’s, one of world’s leading provider in tax training, is exclusively provided by The Tax Guild in India.

Focusing on the OECD Transfer Pricing Guidelines, this diploma addresses the importance of transfer pricing, its legal framework, practical application of the arm’s length principle, apart from focusing on specific issues like intangible assets, business restructuring, cross border financing etc. Additionally, the course also touches upon and provides reference to Indian transfer pricing rules and regulations.

Taught in a modular format, this course is ideal for anyone seeking structured formal learning in the field of transfer pricing. The course has been split in four modules of learning and assessment, followed by the final diploma exam. On successful completion of the final diploma exam, participants will be awarded the Diploma in Transfer Pricing from ATT.

The instructing team of this course comprises highly experienced professionals with Masters in International Tax degrees from leading Universities such as Vienna University, Georgetown University, King’s College London, or professional degrees such as Chartered Accountancy.

Additionally, this course and Instructors are guided by the Academic Board of The Tax Guild which comprises eminent tax professionals of India each of whom have nearly three decades of experience in the field of International tax, and have been involved with transfer pricing since its introduction in India two decades ago.