Introduction to transfer pricing

Build an excellent foundation in the basic principles of transfer pricing for international operations and develop strategies that work to reduce tax risk.

Event Details

Location and date:
Online On-Demand Event

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.

Specializing in transfer pricing?

Then register for our more advanced, three-day In-Depth Transfer Pricing after completing this course.

View the agenda

Additional options and pricing may be available. See pricing and registration for more details.

Members $765; Non-members $895

12 CPD hour(s)
Pricing & registration

You will learn about:

  • the recently updated OECD guidance and Canadian legislation
  • understanding your business and its role in the transfer pricing landscape
  • transfer pricing methodologies (traditional transaction methods, CUP, resale price, cost plus)
  • transactional profit methods:
    • transactional net margin method (TNMM)
    • profit split
  • comparability analysis including factors, adjustments and application
  • financial analysis and statistical methods

Who should attend?

Professional accountants, lawyers, economists and other professionals who are responsible for, or are exposed to transfer pricing, corporate or international taxation, such as:

  • advisors to Canadian corporations with existing or planned foreign operations
  • personnel of Canadian businesses responsible for:
    • transfer pricing
    • corporate tax
    • international tax and/or global taxation
    • government personnel who deal with international tax issues and transfer pricing

More Details:

Session Descriptions

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 Plus

Transactional Profit Methods – Transactional Net Margin Method (TNMM), Profit Split

Determination 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

You may also be interested in:

Deepen your knowledge about transfer pricing and international operations during this in-person course taught by leading Canadian experts.


Please contact:

Member Development and Support
Tel: 1-800-268-3793

Sheri Price, program manager, Member Development and Support
Tel: 416-204-3425