Transfer Pricing Fundamentals - A Practical Workshop

Introduction

Transfer pricing is a key area of tax compliance for businesses operating internationally. Are you confident your organisation or clients can identify the relevant transactions, establish appropriate pricing and support the approach taken?

Expert speaker Rafaela Oplopoiou-Chapman will provide a practical introduction to the OECD framework and UK rules, covering the arm’s length principle, functional analysis, pricing methods and documentation.

This comprehensive face-to-face workshop combines practical explanations with detailed worked examples, interactive exercises and opportunities for discussion. A case study running throughout the session will help you connect the principles and apply them to real-world business arrangements.

It is ideal for compliance staff, in-house tax professionals, junior finance managers, accountants and legal advisers seeking a strong foundational understanding of transfer pricing. No previous specialist knowledge is required.

What You Will Learn

This workshop will cover the following:

• Understanding Transfer Pricing - The Basics
• What transfer pricing is, common misconceptions and why it matters
• Core OECD and UK principles, including when the rules apply, exemptions and adjustments
• Identifying relevant transactions and understanding the risk of double taxation
• Functional Analysis - Laying the Groundwork
• Applying the arm’s length principle through an analysis of functions, assets and risks
• Understanding the value chain, commercial substance and typical entity roles
• Practical exercise - developing a functional profile and assessing risk allocation
• Transfer Pricing Methods and Comparability
• The five OECD methods and selecting the most appropriate approach
• Comparability, benchmarking, financial indicators and arm’s length ranges
• Worked examples - calculating and assessing returns for distributors, manufacturers and service providers
• Applying Transfer Pricing in Practice
• Pricing common arrangements, including intragroup services, management charges and royalties
• Implementing policies, monitoring financial results and managing year-end adjustments
• Integrated case study - linking the functional profile to method selection and pricing
• Financial Transactions and Intangible Assets
• Intercompany loans, guarantees and cash pooling - pricing and substance considerations
• Thin capitalisation and the relationship between funding arrangements and transfer pricing
• Intangible assets, legal ownership and Development, Enhancement, Maintenance, Protection and Exploitation (DEMPE)
• Documentation and Dispute Resolution
• UK documentation requirements, master files, local files and policy memoranda
• Building a defensible position - supporting evidence, intercompany agreements and common documentation gaps
• Preparing for HMRC enquiries and understanding Advance Pricing Agreements, Advance Thin Capitalisation Agreements and Mutual Agreement Procedures
• Managing Transfer Pricing and Recent Developments
• Establishing proportionate controls and coordinating tax, finance, legal and operational teams
• Managing documentation cycles, stakeholder reviews and the use of external advisers
• Relevant UK and OECD developments, including Amount B and an overview of Pillar One, Pillar Two and digital economy implications
• Case study review - identifying risks and developing a practical action plan