Advanced Transfer Pricing

This advanced transfer pricing course looks at the creation of a planning system for tax professionals, enabling them 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
• Advanced sessions review the documentation required, both internal and external
• The intellectual property aspects
• Mutual agreement procedures

Throughout this advanced session, we build up the transfer pricing documentation. Upon completion of training, you will be equipped with a full 'document bible'.

Participants review the appropriate testing methodologies and sample-based checks necessary to robustly substantiate and defend the transfer pricing policies implemented by the company.

Document Bible

During this advanced transfer pricing course, you will create a 'Bible' of documents - all compliant with the new OECD recommendations:

• The master file
• Local file
• Country-by-country reporting 
• A functional analysis of the multinational group
• Specific areas include:
  • R&D
  • Logistics
  • Marketing
  • Sales
  • Channel management
  • Strategic responsibilities

Sessions provide guidance on when these documents should be reviewed and updated, together with approaches to assessing and allocating the optimal level of resources required.

RACI

• Participants will learn how to differentiate between responsibility, accountability, consultation, and information
• Sessions include 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.

At Redcliffe Training, our Advanced Transfer Pricing course is led by a highly experienced taxation professional. In their current role, they are the Director of a consultancy specialising in tax strategy, share schemes, and executive reward.

With over 25 years of direct industry expertise, this specialist 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 advanced transfer pricing - two areas known for their conceptual and practical complexity.

Before founding his own consultancy practice, this expert spent almost nine years at Henderson, leading the Share Schemes team. Earlier in his career at Australian Mutual Provident (AMP), he played a key role in pioneering 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.

Preceding Redcliffe’s advanced transfer pricing course, the trainer’s early career was spent with three of the "Big Four" accountancy firms. It was here that he gained a depth of 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 position at Deloitte, following a sustained trajectory of senior responsibility in taxation.

Outside of his professional commitments, he maintains a keen interest in cricket, history, skiing, tennis, and gardening. He frequently delivers lectures on historical topics, which enhances the depth, clarity, and engagement of his presentation style.

By the end of this advanced transfer pricing course, participants will have acquired a detailed and practical understanding of how to approach transfer pricing from a compliance and risk management perspective, supported by structured frameworks and tools to strengthen organisational positioning and reduce exposure to regulatory challenge.

• Participants will be equipped to create a comprehensive “document bible”, helping to mitigate transfer pricing risks and ensuring compliance with tax authority requirements
• Sessions give detailed insights and a structured framework for developing essential documentation, from internal policies to dealing with inquiries from tax authorities
• Upon completion, delegates are empowered to adopt strategies to strengthen their organisation’s position in advanced transfer pricing matters, ultimately reducing the risk of costly investigations and minimising professional fees during tax audits or disputes
• This advanced transfer pricing course ensures you’ll confidently know how to efficiently monitor and manage specific arrangements, safeguarding the company from reputational and financial risks

This course is suitable for:

• Finance Directors
• Chief Financial Operators
• Senior personnel within the taxation department
• Any 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 financial penalties and reputational damage for companies failing 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.

At Redcliffe Training, our advanced transfer pricing course provides participants with the tools and knowledge to effectively plan, control, and document the specific arrangements. Building on a foundational understanding of transfer pricing, advanced sessions focus on creating a critical “document bible”. This is 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 learn how to strategically manage transfer pricing policies, document transactions and meet the ever-evolving requirements of compliance. Training is essential for finance professionals looking to stay ahead of necessary regulations whilst avoiding the costly consequences of non-compliance.