Advanced Transfer Pricing

This is an advanced transfer pricing course that looks at the creation of a planning system for tax professionals to control the transfer pricing planning process. 

Course Overview

• How to conduct a feasibility study to determine potential transfer pricing risks
• Risk assessment on transfer pricing
• Valid Transfer Pricing data and methodologies
• Documentation required, both internal and external
• The intellectual property aspects
• Mutual agreement procedures

Throughout this advanced transfer pricing course, we build up the transfer pricing documentation. By the end of the day, you will be equipped with a full 'document bible'.

We also look at the testing and sample checking that should be done to substantiate the transfer pricing policies adopted by the company.

Document Bible

• How to create a 'Bible' of documents that comply with the new OECD recommendations
• The master file
• Local file
• Country-by-country reporting 
• A functional analysis of the multinational group
• Specific areas:
  • R&D
  • Logistics
  • Marketing
  • Sales
  • Channel management
  • Strategic responsibilities

The course will also give guidance on when these documents need to be updated and how to assess the optimal resources required.

RACI

• How to differentiate between responsibility, accountability, consultation, and information
• Creating a RACI grid across the Multinational Group.

Case Studies

• Using “Chatham House Rules” we look at your specific position and the requirements for documentation.

Redcliffe Training’s Advanced Transfer Pricing course is led by a highly experienced taxation professional, currently, the Director of a consultancy specialising in tax strategy, share schemes, and executive reward. With over 25 years of industry expertise, the trainer has designed bespoke tax solutions for small businesses and consulted with FTSE 100 companies on complex communication and tax issues. His lecturing portfolio spans a wide range of Direct Taxation topics, with a particular focus on employment taxation and transfer pricing—two areas known for their conceptual and practical complexity.

Before founding his consultancy, he spent almost nine years at Henderson, where he led the Share Schemes team, and earlier at Australian Mutual Provident (AMP), where he pioneered one of the UK’s first Share Incentive Plans (SIPs). His innovative work in SIP design even prompted HMRC to seek his advice on promoting this incentive to larger corporations.

The trainer’s early career was spent with three of the "Big Four" accountancy firms, where he gained deep experience in key areas such as profit-related pay, expatriate tax, share schemes, tax investigations, and, notably, transfer pricing. His career culminated in a Senior Manager role at Deloitte. Outside of his professional work, he enjoys cricket, history, skiing, tennis, and gardening, and often delivers lectures on historical topics, which keeps his presentation style dynamic and engaging.

By the end of this advanced transfer pricing course, participants will:

• Be equipped to create a comprehensive “document bible” that will help mitigate transfer pricing risks and ensure compliance with tax authority requirements.
• Gain detailed insights and a structured framework for developing essential transfer pricing documentation, from internal policies to dealing with inquiries from tax authorities.
• Be empowered to adopt strategies that strengthen their organisation’s position in transfer pricing matters, thereby reducing the risk of costly investigations and minimising professional fees during tax audits or disputes.
• Understand how to efficiently monitor and manage transfer pricing arrangements to safeguard the company from reputational and financial risks.

This course is suitable for:

• Finance Directors
• Chief Financial Operators
• Senior personnel within the taxation department
• Any other key personnel who have responsibilities for transfer pricing policies and their implementation

Transfer pricing, while not a new concept, has become a focal point for tax authorities globally. The increased scrutiny of multinational corporations and their cross-border tax arrangements has heightened the risk of both financial penalties and reputational damage for companies that fail to adequately manage their transfer pricing activities. With more rigorous enforcement by HMRC and other revenue authorities, coupled with public and media attention on tax avoidance, companies are facing ever-greater pressure to ensure compliance.

Redcliffe Training’s Advanced Transfer Pricing course provides participants with the tools and knowledge to effectively plan, control, and document transfer pricing arrangements. Building on a foundational understanding of transfer pricing, the course focuses on the creation of a critical “document bible”—a collection of essential records that not only facilitate day-to-day management but also serve as the first line of defence in the event of a tax authority inquiry.

Through this course, participants will learn how to strategically manage transfer pricing policies, document transactions, and meet the ever-evolving compliance requirements. This training is essential for finance professionals looking to stay ahead of transfer pricing regulations and avoid the costly consequences of non-compliance.