Transfer Pricing Fundamentals - A Comprehensive Guide

Introduction

Transfer pricing is becoming one of the most critical areas of tax compliance worldwide, with governments intensifying efforts to ensure multinational profits are taxed where value is truly created. Are you confident your organisation or clients are prepared to meet these complex challenges?

Expert speaker Rafaela Oplopoiou-Chapman will provide you with an introductory guide through the OECD framework, including the arm’s length principle, functional analysis, and pricing methods, while also providing insight into UK rules.

Designed for those seeking a strong foundational understanding of transfer pricing, this practical, case study driven session will equip you with the tools to navigate real-world transfer pricing challenges in your own organisation or client work. It is ideal for compliance staff, in-house tax professionals, junior finance managers, and legal advisors.

What You Will Learn

This live and interactive session will cover the following:

Understanding Transfer Pricing - The Basics

• Common transfer pricing misconceptions
• What transfer pricing really is and why it matters
• Core OECD and UK legal principles
• When transfer pricing rules apply (including exemptions)
• Transfer pricing adjustments

Functional Analysis - Laying the Groundwork

• Applying the arm’s length principle
• How to perform a functional analysis - functions, assets, and risks
• Practical walk-through of a functional profile
• Value chain analysis basics
• Understanding and allocating risk in an OECD-compliant way
• Transfer Pricing lifecycle - Planning, pricing, documentation, defence
• Identifying typical entity roles - Limited Risk Distributors, toll manufacturers, cost centres

Transfer Pricing Methods

• Overview of the 5 OECD-approved methods
• Choosing a method based on the functional profile
• How to establish comparability
• Role of benchmarking and databases
• Comparability adjustments

Financial Transactions and Intangible Assets

• OECD guidance on financial transactions - Key takeaways
• Intercompany loans, guarantees and cash pooling - Pricing and substance
• Development, Enhancement, Maintenance, Protections and Exploitation (DEMPE) and the treatment of intangible assets

Preparing Transfer Pricing Documentation and Dispute Resolution

• Transfer pricing documentation - Local file, master file and transfer pricing policy memo
• Transfer pricing audits - What to expect and how to prepare
• Overview of Advance Pricing Agreements (APA) and Thin Capitalisation Agreements
• Mutual Agreement Procedures (MAP) under tax treaties
• Dealing with audits and transfer pricing enquiries

Practical Considerations and Recent Developments

• Setting up a transfer pricing control framework
• Working with advisors vs. doing it in-house
• Role of finance, tax, and operations
• Managing documentation cycles, deadlines, and stakeholder reviews
• Recent global developments:
• OECD Pillar One and Pillar Two
• Digital economy and transfer pricing implications

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.