Basic knowledge of transfer pricing

Introduction

• Concept and function of transfer pricing.
• Legal background and tax implications.
• Concept of the arm's length principle.

Implementation of the arm's length principle and transfer pricing methods

• The price comparison method.
• The cost-plus method.
• The resale price method. 
• The transactional net margin method.
• The transactional profit split method.
• The hypothetical arm's length comparison. 

Business units affected and types of transactions

• Deliveries of goods and merchandise.
• services and Group allocations.
• Sale and licensing of intangible assets.
• Financing.
• Secondment of personnel.

Process-related requirements

• Processes for designing and monitoring transfer prices.
• Compliance with legal documentation requirements.

Contents of the documentation requirements - national and international

• Overview of the creation of documentation.
• Implementation of transfer pricing documentation.
• Maintenance of transfer pricing documentation.

Typical tax audit risks and tax profit corrections

Developments at national and international level (OECD, EU) and their impact in the future