Description

Type

Intensive workshop
Level

Intermediate
Methodology

Online
Class hours

15h
Duration

4 Weeks

Start date

Different dates available
Online campus

Yes
Delivery of study materials

Yes
Support service

Yes
Personal tutor

Yes

The aim of this module is to highlight the legal framework that covers Transfer Pricing. Transfer Pricing touches multinational corporations, working in multiple jurisdictions. This module will give the student an overview of looking at the legal environment of a specific jurisdiction when applying the transfer pricing principles. This is a very broad module, however, it lays the foundation for the rest of the course. The appreciation of operating within an ethical framework and specifically within the Transfer Pricing environment is discussed with the students.

The module also covers the very important Arm’s Length Principle and Functional Analysis, laying further groundwork for the rest of the course.

The "Arm's-Length Principle" of transfer pricing states that the amount charged by one related party to another for a given product must be the same as if the parties were not related. An arm's-length price for a transaction is therefore what the price of that transaction would be on the open market.

The functional analysis is used for transfer pricing purposes. It analyzes the functions performed (taking into account assets used and risks assumed) by associated enterprises in a transaction.

Facilities

Online

Start date

Different dates availableEnrolment now open

About this course

Course objectives

On completion of this module the successful student will be able to:

1.understand and be able to explain the basic overview of Transfer Pricing and why it is important for enterprises
2. fully appreciate the ethical considerations from a legal perspective and specifically how this is interwoven into the foundational aspects of Transfer Pricing
3. interpret and analyse Transfer Pricing regulations and be able to source these regulations
4. interpret and explain Transfer Pricing Case Law by studying actual prior Court Case summaries
5.explain the sections relating to Transfer Pricing within the United Nations and OECD Model Tax Convention, with specific reference to Articles 7, 9, 10, 11 and 12
6. provide a detailed understanding of the Arm’s Length Principle and the various fundamental concepts relating to the Arm’s Length Principle
7. explain the term, Functional Analysis, as set out in the OECD Guidelines and be able to provide a critical outline of the various steps required by a Functional Analysis
8. understand and compare the various TP methods as provided in the OECD Guidelines
9. critically analyse each of the TP methods and to know which TP method to apply to a specific transaction

Who is it intended for?

Transfer Pricing Managers
Finance Directors
Group Tax Directors
Heads of Corporate Tax
Tax Accountants
Lawyers
Heads of Transfer Pricing
Senior Tax Managers
Senior Executives
Accountants

What marks this course apart?

This is the only online course that covers Transfer Pricing in this detail. Developed from the Postgraduate Diploma in Transfer Pricing as offered by I/I/T/F and Middlesex University. The quality and and depth of knowledge of the lecturers is unrivalled in this field.

What happens after requesting information?

On making a request our academic representative will reach out to you with any further information you require

What career prospects are there

Transfer Pricing Managers
Finance Directors
Group Tax Directors
Heads of Corporate Tax
Tax Accountants
Lawyers
Heads of Transfer Pricing
Senior Tax Managers
Senior Executives
Accountants

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Reviews

Subjects

10-12 of the OECD and UN Model Tax Convention
In order to delineate such transactions
The availability of reliable information

Teachers and trainers (4)

Dr Daniel N. Erasmus

Independent Tax Court Counsel & Senior Lecturer

A globally-experienced international and litigation tax attorney that consults in the US (on international tax and Africa related tax issues) and all over Africa advising (with court appearances where required), and training clients how to address tax issues successfully arising from domestic and international tax (incl. BEPS, transfer pricing & dispute resolution issues), in various African countries incl. South Africa, Mauritius, Zimbabwe, Zambia, Malawi, Tanzania, Uganda, Kenya, Nigeria and Ghana).

Okkie Kellerman

Independent Consultant - Transfer Pricing & International Tax

Okkie Kellerman is an independent consultant in the areas of international taxation and transfer pricing. He was peviously an executive at ENSafrica, the largest legal firm in Africa. He is a qualified chartered accountant and specialises in international tax (with special emphasis on inward and outward investments and the funding of transactions such as restructurings, take-overs and merger and acquisition), transfer pricing, thin capitalisation, the application of international double tax agreements and exchange control regulations.

Renier van Rensburg

CFO

Vast experience in managing financial departments (small to big). Spent most of my time implementing systems and coordinating efforts in the streamlining of the various administrative tasks associated with growing administrative and operational divisions within Group's of companies. Broad experience in liaising with internal & external shareholders in complex legal environments Specialties: Simplifying complexity within day-to-day operations, Convergence of business strategy from Head Office perspective

Solomon Choge

Head of Sales at RoyaltyRange

Specialist with a demonstrated history of working in the information services industry. Skilled in Transfer Pricing, International Tax, Tax Advisory, Tax Law, and Corporate Tax. Strong sales professional focused on Databases and Software for Transfer Pricing and Tax purposes with a LLM Mercantile Law & H-Dip International Tax.

Course programme

This module is split into 7 Lectures

1. What is International Taxation

2. Overview of International Taxation

3. Principles of Taxation - Definitions (1 Week)

4. Principles of Taxation - Application (1 Week)

5. How International Taxation came into force (1 Week)

6. Model Tax Conventions (1 Week)

7. Other International Law (1 Week)

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