Introduction to transfer pricing
This course was designed for tax practitioners who wish to build a strong foundation of the basic principles of transfer pricing for international operations and develop effective strategies to reduce tax risk.
Are you a tax practitioner who would like a better understanding of the foundational principles of transfer pricing? If so, this course is for you.
The material in this course reflects legislative changes as of October 31, 2021.
- what transfer pricing is and why it is important
- the definition of the arm’s length principle
- controlled and uncontrolled transactions
- types of intercompany transactions
- transfer pricing methods
- comparability factors
- an overview of s.247 of the Income Tax Act
- form T106 reporting
- country-by-country reporting
- dispute resolution processes and procedures
- the differences between United States and Canada transfer pricing regimes
- recent transfer pricing court cases
- 2017 OECD Guidelines and the OECD’s base erosion and profit shifting (BEPS) project
- Tax practitioners who wish to gain a foundational understanding of Canadian transfer pricing
