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Advanced Transfer Pricing

Planning, control and compilation of documents

Advanced Transfer Pricing Course

A one-day course

This course is designed to equip participants with the necessary tools to create a comprehensive “document bible” to allow for the extensive monitoring of transfer pricing arrangements. It therefore goes beyond the normal discussion of the principles of transfer pricing.

This is a highly practical course rather than a theoretical one and builds on the principles in transfer pricing.

  • Participants should be in a position to create a “document bible” which will allow companies to mitigate the effects of transfer pricing challenges that tax authorities may launch.
  • At the end of the course, the participants will have detailed guidance and a framework for creating the necessary transfer pricing documentation to deal with the both companies internal policies and any tax authority enquiry.
  • The adoption of this strategy puts the company in a strong position in dealing with transfer pricing and would reduce the professional costs it would incur in any investigation.

Although the concept of Transfer Pricing is not new it is the focus of increased attention by Revenue authorities across the world and can result in the diversion of substantial resources and costs in terms of a final tax settlement.

The activities of some well-known multinationals have provoked severe responses in terms of the media and public opinion, leading to not only tax issues but also reputational risk. In the UK, Parliament has put more pressure on Revenue authorities to deal more robustly with “aggressive tax avoiders”. Inevitably, more companies will find themselves under the microscope.

The course looks at the planning and control of Transfer Pricing issues.

The course assumes that participants have a basic knowledge of transfer pricing and looks to build on this by creating a bundle of documents which are crucial in the control of transfer pricing issues and the planning of how a company should deal with the recording of transfer pricing transactions and the documentation that is essential for every company to maintain.

  • Recent transfer pricing developments
  • How to conduct a feasibility study to determine potential transfer pricing risks
  • Valid Transfer Pricing data and methodologies
  • Presentation to the Board
  • Documentation required from both internal and external sources
  • The intellectual property aspects
  • Keeping transfer pricing documentation relevant and up to date-practical challenges

Throughout the training we build up the transfer pricing documentation so by the end of the training the participants are 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.

Case Studies - Using “Chatham House rules” we look at the participants individual position and their specific requirements for documentation.

The trainer is a Director of a consultancy company specialising in taxation, share scheme advice, reward and lecturing. He has developed a specialised share scheme service for small companies and advises FTSE companies on communication. The lecturing covers most aspects of Direct Taxation but his particular interests include employment taxation and transfer pricing, which poses unusual conceptual challenges.

Previous to this he worked for Henderson for nearly 9 years, leading the Share Schemes team for part of this time.

He took the level 7 CIPD Masters qualification whilst at Henderson.

Before Henderson, he was with Australia Mutual Provident (AMP) and helped set up one of the first Share Incentive Plans (SIP) for large companies in 2001. It was so unusual at the time that the Revenue phoned him up to find out how they could encourage more large companies to adopt SIP.

The trainer started his career in taxation and for the next 16 years worked in three of the “Big Four” accountancy firms. He ended up as a Senior Manager with Deloitte & Touche, having worked on issues such as profit related pay, share schemes, expatriate tax, tax investigations, reward management, US taxation, transfer pricing and corporate tax.

The creation of a planning system for tax professionals to control the transfer pricing planning process. This is an advanced course for those who understand the basic principles of transfer pricing.

This course is suitable for Finance Directors, Chief Financial Operators, Senior personnel within the taxation department and any other key personnel who have responsibilities for Transfer Pricing policies and their implementation.

Have this course presented In-House

  • On a date, time and in a location of your choice
  • Topics expanded or deleted to your bespoke requirements

Have this course pre-recorded

  • Full course recording edited exclusively for your company
  • Files converted to enable housing on your LMS

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