Transfer Pricing Fundamentals

Fundamental Transfer Pricing Issues

• Pricing theory and its relevance to current tax issues
• Risk Assessment on Transfer Pricing
• Valid Transfer Pricing data and methodologies:
  • Consideration of the different OECD-approved transfer pricing methods
  • Cost plus
  • Transactional net margin method
  • Profit split
  • Residual profit split
  • Resell minus.
  • The use of comparable uncontrolled pricing (CUP)
• Building up your defences against HMRC action
• How to conclude a settlement
• Mutual agreement procedures
• Relevant case law
• Interaction with the Diverted Profits Tax

For in-house tax teams, our transfer pricing courses have been designed to bring together the different departments that have an impact on Transfer Pricing, this includes:

• Finance
• Legal
• HR
• Company secretarial

Throughout the day, there will be a series of case studies which look at the impact of Transfer Pricing on different locations in which the business is situated and the varying departments.

Bringing Transfer Pricing Up-to-Date

Although the concept of Transfer Pricing is not new it is the focus of increased attention by Revenue authorities 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 turn, 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.

In 2019 HMRC acquired new powers in respect of countering “profit fragmentation”. This marks a radical departure from previous legislation on transfer pricing as there is no exemption for small and medium-sized companies.

This Transfer Pricing Fundamentals course is led by an accomplished taxation expert, currently, the Director of a consultancy specialising in tax strategy, share schemes, and executive reward. With over 25 years of professional experience, the trainer has worked closely with both small and FTSE 100 companies, offering tailored advice on tax-related communication and compliance. His lecturing expertise spans a wide array of Direct Taxation topics, with a particular focus on the intricacies of employment taxation and transfer pricing—two areas often presenting complex conceptual and operational challenges.

Before founding his consultancy, he spent nearly a decade at Henderson, where he played a key role in leading the Share Schemes team. His career highlights also include pioneering one of the UK’s first Share Incentive Plans (SIP) while working for Australian Mutual Provident (AMP), a ground-breaking initiative that even drew the attention of HMRC for its innovative approach.

With 16 years of experience at three of the "Big Four" accountancy firms, he has worked on a wide variety of taxation issues, including profit-related pay, expatriate tax, share schemes, and transfer pricing. His career culminated in a Senior Manager role at Deloitte, where he gained in-depth knowledge of global tax strategies. Outside of his professional career, he maintains a keen interest in cricket, history, skiing, and tennis, and frequently gives historical lectures, which enhances his dynamic teaching style.

By the end of the Transfer Pricing course, participants will:

• Gain a thorough understanding of the OECD principles that govern transfer pricing, with an emphasis on the framework established by the OECD model treaty.
• Understand the significant changes introduced by the Base Erosion and Profit Shifting (BEPS) process, and how they impact transfer pricing strategies and compliance requirements.
• Learn to apply transfer pricing principles in a practical context, with a focus on navigating the tax regimes of individual states, particularly the UK and the US, ensuring compliance with varying international rules.
• Redcliffe’s transfer pricing courses ensure you will be better equipped to recognise and mitigate transfer pricing risks that multinational companies face, and adopt strategies that align with both regulatory demands and business objectives.

This course is tailored to appeal to both seasoned tax specialists and professionals whose disciplines intersect with transfer pricing, offering valuable insights for a broad audience. Unlike other courses that focus solely on the taxpayer’s perspective, this training provides a balanced approach by examining the objectives of both multinational companies and Revenue Authorities. Participants will learn how tax authorities structure their transfer pricing policies and how businesses can effectively manage these challenges while minimizing risk.

The transfer pricing course also goes beyond theory by offering practical, actionable insights. It delves into the real-world application of transfer pricing principles, particularly in light of BEPS reforms and changing global tax policies. With its blend of practical exercises and comprehensive coverage of legislative frameworks, this course provides participants with the tools they need to safeguard their companies from transfer pricing disputes.

This Transfer Pricing Fundamentals course provides a comprehensive overview of how transfer pricing operates within the context of both legislation and practical application. We address the foundational principles of transfer pricing and equip you with the knowledge needed to comply with international regulations.

Over six hours (for both online and in-house formats), participants will explore the key elements of transfer pricing, including its legislative underpinnings and real-world execution. Special emphasis is placed on understanding the global tax landscape, with case studies focused on UK and US practices, allowing professionals to confidently navigate the complexities of transfer pricing in today’s regulatory environment.

By the end of the course, attendees will be well-versed in both the theory and application of transfer pricing, enabling them to effectively manage compliance and mitigate risk for their organisations.