Pideya Learning Academy

International Taxation and Transfer Pricing Frameworks

Upcoming Schedules

  • Schedule

Date Venue Duration Fee (USD)
11 Aug - 15 Aug 2025 Live Online 5 Day 2750
01 Sep - 05 Sep 2025 Live Online 5 Day 2750
27 Oct - 31 Oct 2025 Live Online 5 Day 2750
24 Nov - 28 Nov 2025 Live Online 5 Day 2750
24 Feb - 28 Feb 2025 Live Online 5 Day 2750
31 Mar - 04 Apr 2025 Live Online 5 Day 2750
26 May - 30 May 2025 Live Online 5 Day 2750
23 Jun - 27 Jun 2025 Live Online 5 Day 2750

Course Overview

Taxation and transfer pricing are pivotal topics in today’s interconnected global economy, significantly impacting multinational enterprises (MNEs) and cross-border operations. Navigating international tax regimes and transfer pricing frameworks is crucial for ensuring compliance, reducing risks, and optimizing financial performance. Recognizing the complexity of these challenges, Pideya Learning Academy presents the International Taxation and Transfer Pricing Frameworks, a comprehensive program tailored for professionals in tax, finance, and accounting.
The global significance of transfer pricing continues to grow. Recent data reveals that in 2021, over 60% of MNEs faced transfer pricing audits, with disputes resulting in billions of dollars in adjustments. The OECD estimates that unresolved transfer pricing disputes cost governments approximately $100 billion annually in potential tax revenue. This demonstrates the critical need for businesses to adopt robust strategies aligned with international guidelines, such as the OECD Transfer Pricing Guidelines and the United Nations’ Model Tax Convention.
The International Taxation and Transfer Pricing Frameworks course empowers participants to master foundational and advanced principles of transfer pricing, with a focus on its application to various industries and business models. Attendees will gain insights into regulatory standards, including the Arm’s Length Principle, and explore methodologies such as the Comparable Uncontrolled Price (CUP) Method, Profit Split Method (PSM), and Transactional Net Margin Method (TNMM). This training emphasizes developing analytical skills to assess policies, draft effective documentation, and align practices with evolving global tax norms.
Key highlights of this training include:
Deep Dive into Global Frameworks: Participants will explore international tax treaties, OECD guidelines, and domestic regulations that govern transfer pricing.
Strategic Transfer Pricing Methods: The course covers advanced methodologies, equipping attendees to choose and implement the best approach for their organizational context.
Focus on Compliance and Risk Mitigation: Attendees will learn to navigate the complexities of global tax audits and disputes while minimizing exposure to penalties.
Emerging Trends in Transfer Pricing: Participants will examine the impact of the digital economy, ESG factors, and artificial intelligence on modern tax practices.
Policy Influence and Legislative Analysis: Attendees will gain tools to analyze tax frameworks and propose improvements aligned with international standards.
Global Case Studies: Real-world scenarios provide a contextual understanding of challenges and solutions in transfer pricing, ensuring actionable takeaways.
Comprehensive Documentation Insights: The course emphasizes the strategic importance of maintaining accurate and compliant transfer pricing documentation.
As the global tax landscape evolves, staying informed and equipped to address these changes is vital for businesses aiming to maintain compliance and competitiveness. With the expertise of Pideya Learning Academy, participants will acquire a competitive edge, ready to tackle the complexities of international taxation and transfer pricing. This training not only enhances technical knowledge but also prepares professionals to shape discussions, drive policy improvements, and achieve organizational success.
By enrolling in this program, professionals can enhance their expertise, bolster their organizations’ compliance efforts, and proactively address the challenges posed by an ever-changing regulatory environment. Whether you’re an experienced tax professional or looking to deepen your understanding, the International Taxation and Transfer Pricing Frameworks course by Pideya Learning Academy offers a structured, industry-relevant learning experience designed for impact.

Key Takeaways:

  • Deep Dive into Global Frameworks: Participants will explore international tax treaties, OECD guidelines, and domestic regulations that govern transfer pricing.
  • Strategic Transfer Pricing Methods: The course covers advanced methodologies, equipping attendees to choose and implement the best approach for their organizational context.
  • Focus on Compliance and Risk Mitigation: Attendees will learn to navigate the complexities of global tax audits and disputes while minimizing exposure to penalties.
  • Emerging Trends in Transfer Pricing: Participants will examine the impact of the digital economy, ESG factors, and artificial intelligence on modern tax practices.
  • Policy Influence and Legislative Analysis: Attendees will gain tools to analyze tax frameworks and propose improvements aligned with international standards.
  • Global Case Studies: Real-world scenarios provide a contextual understanding of challenges and solutions in transfer pricing, ensuring actionable takeaways.
  • Comprehensive Documentation Insights: The course emphasizes the strategic importance of maintaining accurate and compliant transfer pricing documentation.
  • Deep Dive into Global Frameworks: Participants will explore international tax treaties, OECD guidelines, and domestic regulations that govern transfer pricing.
  • Strategic Transfer Pricing Methods: The course covers advanced methodologies, equipping attendees to choose and implement the best approach for their organizational context.
  • Focus on Compliance and Risk Mitigation: Attendees will learn to navigate the complexities of global tax audits and disputes while minimizing exposure to penalties.
  • Emerging Trends in Transfer Pricing: Participants will examine the impact of the digital economy, ESG factors, and artificial intelligence on modern tax practices.
  • Policy Influence and Legislative Analysis: Attendees will gain tools to analyze tax frameworks and propose improvements aligned with international standards.
  • Global Case Studies: Real-world scenarios provide a contextual understanding of challenges and solutions in transfer pricing, ensuring actionable takeaways.
  • Comprehensive Documentation Insights: The course emphasizes the strategic importance of maintaining accurate and compliant transfer pricing documentation.

Course Objectives

After completing this Pideya Learning Academy International Taxation and Transfer Pricing Frameworks, participants will:
Understand the links between various fiscal laws and their implications for businesses.
Identify key legal and policy challenges and evaluate best practice solutions for addressing them.
Assess domestic tax legislation against global standards and recommend improvements.
Develop strategies for effective transfer pricing implementation to ensure compliance and minimize risks.
Effectively explain and advocate for proposed legislative changes during stakeholder consultations.

Personal Benefits

Participants in this course will gain:
Advanced knowledge of international taxation and transfer pricing principles.
Skills to analyze and interpret complex tax regulations confidently.
The ability to develop and implement effective strategies to address transfer pricing challenges.
Expertise in engaging stakeholders and influencing tax policy discussions.
A prestigious certificate of completion from Pideya Learning Academy to enhance professional credentials.

Organisational Benefits

Who Should Attend

This Pideya Learning Academy Certificate Course is ideal for professionals involved in financial planning, compliance, and strategic decision-making, including:
Financial accounting team members
Cost and management accounting staff
Finance managers and directors
Budget managers
Commercial managers
Capital investment and project team members
Investment analysts and acquisition team members
Risk managers
By participating in this course, attendees will be well-prepared to address the complex challenges of international taxation and transfer pricing, positioning themselves and their organizations for success in a competitive global market.

Course Outline

Module 1: Fundamentals of Transfer Pricing
Understanding the Concept of Transfer Pricing Importance of Transfer Pricing in Multinational Enterprises (MNEs) Business Models in MNEs and Intra-Group Relationships Separate Entity Concept: Definition, Applications, and Case Studies Economic Implications of Transfer Pricing on States Transfer Pricing in Relation to MNE Group Structures
Module 2: Transfer Pricing Regulatory Frameworks
Overview of Domestic Transfer Pricing Regulations International Taxation Landscape and Transfer Pricing Key Features of Transfer Pricing Legal Frameworks Arm’s Length Principle: Core Concepts and Applications Comparative Analysis of Global Formulary Apportionment United Nations Models: Articles 9 and 25 OECD Transfer Pricing Guidelines: Key Takeaways
Module 3: Methodologies in Transfer Pricing
Comprehensive Overview of Transfer Pricing Methods Cost-Plus Method: Key Variables and Use Cases Transactional Net Margin Method (TNMM): Technical Insights Resale Price Method (RPM): Key Determinants Profit Split Method (PSM): Strategic Applications Comparable Uncontrolled Price (CUP): Evaluation Standards Commodity Pricing Rules and Sector-Specific Applications
Module 4: Transfer Pricing Adjustments
Understanding the Adjustment Process in Transfer Pricing Primary Adjustments: Process and Challenges Secondary Adjustments and Their Tax Implications Repatriation Strategies in Transfer Pricing Contexts Step-by-Step Approach to Compensating Adjustments Corresponding Adjustments and Cross-Border Disputes
Module 5: Transfer Pricing Documentation
Strategic Objectives of Transfer Pricing Documentation Domestic Transfer Pricing Documentation Rules and Standards Insights from OECD Transfer Pricing Guidance (Chapter V) United Nations Guidance on Transfer Pricing Documentation Key Compliance Challenges in Transfer Pricing Documentation
Module 6: Advanced Topics in Transfer Pricing
Digital Economy and Transfer Pricing Implications Transfer Pricing in the Context of Intellectual Property Rights Impact of Transfer Pricing on Supply Chain Management Transfer Pricing Risk Management and Mitigation Transfer Pricing in the Context of Emerging Markets
Module 7: Transfer Pricing in Dispute Resolution
Transfer Pricing Dispute Prevention Mechanisms Arbitration and Mutual Agreement Procedures (MAPs) Role of Advance Pricing Agreements (APAs) in Mitigating Disputes Transfer Pricing Litigation: Strategies and Case Analysis
Module 8: Emerging Trends and Future Perspectives
Evolution of Transfer Pricing Regulations Globally ESG (Environmental, Social, Governance) Impact on Transfer Pricing Policies The Role of Artificial Intelligence in Transfer Pricing Compliance Global Consensus Efforts and the Role of BEPS (Base Erosion and Profit Shifting)

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