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Build an excellent foundation in the basic principles of transfer pricing for international operations and develop strategies that work to reduce tax risk.
This exciting introductory-level offering has been recently updated to reflect the latest guidance from the Organisation for Economic Co-operation and Development (OECD) and Canadian legislation. It will provide grounding in the basic principles of transfer pricing and explore some of the more critical issues and fundamental strategies that international businesses need to understand.
All six of the elearning modules in this course have been designed to complement the extensive pre-reading materials which you must complete prior to accessing the streaming media presentations. Once you have finished both the pre-readings and the streaming media components, you will be required to successfully complete a quiz before moving on to the next module.
Additionally, there will be two interactive webinar "checkpoints" that give you the opportunity to submit questions and interact with a senior transfer pricing professional to discuss topics covered in the modules.
Transfer Pricing not only offers the flexibility and convenience of online study, it also delivers foundational transfer pricing knowledge to help you succeed as a tax professional today.
Then register for our more advanced, three-day In-Depth Transfer Pricing after completing this course.
Additional options and pricing may be available. See pricing and registration for more details.
Professional accountants, lawyers, economists and other professionals who are responsible for, or are exposed to transfer pricing, corporate or international taxation, such as:
Module 1: An introduction to transfer pricing
• What is transfer pricing and how does it impact your businesses’ profits, reporting, customs, and taxes?• Introduction to OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations• Arm’s length principle. Introduction to primary source Canadian transfer pricing legislation and guidance, such as adjustments, recharacterization, penalties and contemporaneous documentation
Module 2: Understanding your business and its role in the transfer pricing landscape
• Introduction to the categories of intercompany transactions (or transfers) including definitions of tangible and intangible property, services, and financial transactions• Impact of global business environment on an entity’s role, risks and profitability• Understanding an entity’s risk-reward profile through analysis of the functions, risks and assets of an entity• Introduction to the types of entities based on role, risk-reward profile and positioning in the value chain
Module 3: Transfer pricing methodologies
Traditional Transaction Methods: Comparable Uncontrolled Price (CUP), Resale Price, Cost PlusTransactional Profit Methods – Transactional Net Margin Method (TNMM), Profit SplitDetermination of method to use. Special considerations for intra-group services: management fees, arm’s length charge
Module 4: Comparability analysis
• Meaning of “comparable”• Comparability factors• Comparability analysis• Comparability adjustments
Module 5: Financial analysis and statistical methods
• Develop an understanding of financial statement issues and considerations• Understanding financial adjustments• Understanding profit level indicators• Understanding ranges and multi-year data
Module 6: Putting it all together
• Transfer pricing policies• Transfer pricing documentation• Financial statement and other disclosures• Transfer pricing monitoring and adjustments• Canada Revenue Agency audit activity• Country-by-country reporting
Deepen your knowledge about transfer pricing and international operations during this three-day, in-person course taught by leading Canadian experts.
Member Development and Support
Sheri Price, program manager, Member Development and Support
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