Transfer Pricing Fundamentals Course Syllabus

Overview: This course provides a clear, practical foundation in global transfer pricing fundamentals, designed for finance professionals and newcomers to international tax. Aligned with OECD standards, it covers core concepts, principles, and compliance requirements. With approximately 3.5 hours of video content, learners will progress through five structured modules, gaining the knowledge needed to understand and apply transfer pricing rules in real-world contexts. Lifetime access ensures flexibility for on-demand learning.

Module 1: Introduction to Transfer Pricing

Estimated time: 0.5 hours

• Define transfer pricing and its role in international taxation
• Understand the concept of multinational enterprises (MNEs)
• Identify associated enterprises and controlled transactions
• Recognize the importance of transfer pricing in tax compliance

Module 2: Arm’s-Length Principle & Comparability

Estimated time: 0.75 hours

• Explain the OECD arm’s-length principle and its legal origins
• Understand the purpose of comparability analysis
• Apply the five OECD comparability factors
• Identify factors affecting comparability in cross-border transactions

Module 3: Functional & Risk Analysis

Estimated time: 0.75 hours

• Conduct a functional analysis of related entities
• Assess financial functions performed and assets used
• Evaluate risks borne by each party in controlled transactions
• Link functional analysis to appropriate profit allocation

Module 4: Transfer Pricing Methods

Estimated time: 1 hour

• Learn the five OECD transfer pricing methods: CUP, RPM, Cost-Plus, TNMM, and Profit-Split
• Compare method reliability and applicability
• Select appropriate methods based on transaction type and data availability
• Understand strengths and limitations of each method

Module 5: Documentation & Compliance

Estimated time: 0.75 hours

• Prepare compliant transfer pricing documentation
• Understand Master File requirements under OECD guidelines
• Prepare Local File components for jurisdiction-specific reporting
• Recognize global compliance obligations including country-by-country reporting

Prerequisites

• Basic understanding of financial statements
• Familiarity with corporate taxation concepts
• No prior transfer pricing experience required

What You'll Be Able to Do After

• Explain key transfer pricing concepts such as controlled transactions and arm’s-length pricing
• Apply the OECD arm’s-length principle to cross-border transactions
• Perform functional and comparability analyses for transfer pricing purposes
• Select and justify appropriate transfer pricing methods using OECD guidance
• Prepare essential documentation including Master File and Local File components