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Course Aims

The aim of this course is to ensure a student can choose and understand the appropriate TP method for controlled transactions, perform a comparability analysis and determine an arm’s length charge for Intra-Group Services.

For TP Methods, the student will fully understand how each method works, the specific conditions for a method to be applied and be able to perform the calculations required for each method.

The module further aims to provide the student with a thorough understanding of the comparability analysis, once the transaction has been delineated and the significant comparability factors taken into account. The comparability analysis is crucial to be able to determine the correction (if any) required to calculate an arm’s length price.

Lastly intra-group services will be studied, to ascertain when these services are rendered, to determine an arm’s length charge for these services and further conditions relating to the application of the OECD guidelines to intra-group services and low value-adding intra-group services.

On successful completion of this module, the student should be able to:

  1. Compare/contrast the various transfer pricing methods that can be used to determine an arm’s length price.
  2. Critically analyse the nine steps of a comparability analysis.
  3. Evaluate the use of comparables in a comparability analysis.
  4. Interpret OECD transfer pricing guidelines surrounding the charging for intra-group services.
  5. Identify which intra-group services can be classified as low value-adding intra group services.

COURSE NOTE:

This course is Module 2 of a 4 Module course on Transfer Pricing.  Each Module stands separately, however, we suggest that you complete all 4 courses in order to get the full benefit of these teachings.

Additional Modules in the whole course are:

  • Module 1 – Transfer Pricing Legal Framework
  • Module 2 (this course) – Sharing Corporate Resources
  • Module 3 – Transfer Pricing Specialised Areas
  • Module 4 – PE’s & Compliance and Dispute Resolution

Course Curriculum

Introduction
Introduction 00:30:00
Lecture 1 - TP Methods (Traditional Methods, including CUP)
Part 1 – Introduction & CUP 00:20:37
Part 2 – CUP in detail 00:21:20
Part 3 – CUP: Advantages & Disadvantages 00:09:41
Lecture 2 - TP Methods (Profit Split Method)
Part 1 – Profit Split Method 00:18:26
Part 2 – Profit Split Method 00:20:11
Part 3 – Profit Split Method 00:11:02
Lecture 3 - TP Methods (TNMM with database examples)
Royalty Range Example 00:44:29
ONESource Example 00:41:26
Lecture 4 - Comparability Analysis 1
Introduction Part 1 00:24:12
Introduction Part 2 00:17:48
Introduction Part 3 00:16:13
Part 4 – Database Introduction 00:27:21
Lecture 5 - Comparability Analysis 2
Part 1 – Intro & Databases 00:15:20
Part 2 – Limitations in available comparables 00:20:15
Part 3 – Potential comparables 00:05:54
Lecture 6 - Comparability Analysis 3
Part 1 – Types of adjustments & working capital adjustments 00:17:04
Part 2 – Purpose of Adjustments 00:19:43
Part 3 – Compliance Issues 00:06:59
Lecture 7 - Intra-Group Services 1
Part 1 – Introduction 00:05:47
Part 2 – Has Intra-Group Service been rendered? 00:15:07
Part 3 – Determining arms length charge 00:09:45
Lecture 8 - Intra-Group Services 2
Part 1 – Intra-Group Service – Special Considerations 00:14:46
Part 2 – Methods 00:20:15
Part 3 – Final remarks on Intra-Group Services 00:13:28

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