Transfer Pricing Fundamentals

Understand the basics of the arm’s length principle and international transfer pricing rules.
Transfer Pricing Fundamentals
File Size :
531.47 MB
Total length :
2h 24m



Borys Ulanenko


Last update

Last updated 2/2021



Transfer Pricing Fundamentals

What you’ll learn

Transfer Pricing
Fundamental sources
What is “multinational enterprise”
What are “intragroup transactions”
What is the “arm’s length principle”
What companies are “associated enterprises”
Which transactions are controlled
Comparability and five OECD comparability factors
Why we need functional analysis
What is entity characterization
Risk analysis framework
Transfer pricing methods
Transfer pricing documentation

Transfer Pricing Fundamentals


Nothing specific – but a very basic understanding of finance/tax is helpful


You probably heard about multinationals’ tax avoidance, tax heavens and cross-border profit-shifting. In the last decade, many multinationals were accused of tax dodging – often, using something called “transfer pricing”. But is transfer pricing bad? What is it, actually?The course gives an overview of international transfer pricing rules and principles and covers the following topics:1) What is transfer pricing, associated enterprises and controlled transactions?2) Why is it relevant from a tax perspective?3) How multinationals can use transfer pricing for tax avoidance?4) What are transfer pricing rules?5) What is the arm’s length principle and where it comes from?6) What is comparability? 7) What is a functional analysis and why is it needed?8) What are five OECD transfer pricing methods and when are they used?9) What is transfer pricing documentation?The course will be useful for every finance, accounting and tax professional who wants to understand what transfer pricing is about and where modern transfer pricing rules come from. If you need to deal with transfer pricing or intragroup transactions, review the transfer pricing documentation or policies, cooperate with consultants – this course is for you! The course will be especially useful for someone preparing for a career in transfer pricing or international tax. The course is not country-specific, as the principles explained in the course are universal around the world.


Lecture 1 Introduction to the course

Section 1: Module 1: Introduction to Transfer Pricing

Lecture 2 Introduction and the Context

Lecture 3 Multinational Enterprises (MNEs)

Lecture 4 Intragroup Transactions

Lecture 5 What is Transfer Pricing?

Lecture 6 The Arm’s Length Principle

Lecture 7 Fundamental Sources of Transfer Pricing Rules

Section 2: Module 2: Mechanics of the Arm’s Length Principle

Lecture 8 Associated Enterprises

Lecture 9 Controlled Transactions

Lecture 10 Comparability

Section 3: Module 3: Functional Analysis

Lecture 11 Introduction to Functional Analysis

Lecture 12 Why Functions, Assets and Risks (FARs) are Important?

Lecture 13 Functional Analysis Example – Simplified

Lecture 14 OECD Risk Analysis

Lecture 15 Entity Characterization

Lecture 16 Functional Analysis and Transfer Pricing Methods

Section 4: Module 4: Transfer Pricing Methods

Lecture 17 Transfer Pricing Methods Overview

Lecture 18 Comparable Uncontrolled Price Method (CUP)

Lecture 19 Resale Price Method (RPM)

Lecture 20 Cost Plus Method (CPM)

Lecture 21 Transactional Net Margin Method (TNMM)

Lecture 22 Transactional Profit Split Method (PSM)

Lecture 23 Comparability Analysis in General

Section 5: Module 5: Transfer Pricing Compliance

Lecture 24 Transfer Pricing Compliance in General

Lecture 25 Transfer Pricing Documentation: Local File, Master File, CbCR

Lecture 26 Transfer Pricing Audits

Lecture 27 What’s next?

Finance and business professionals interested in transfer pricing and international tax,Someone who has to deal with transfer pricing and needs a basic understanding of key transfer pricing concepts,Finance and accounting folks dealing with intragroup transactions,International tax specialists considering move to transfer pricing field

Course Information:

Udemy | English | 2h 24m | 531.47 MB
Created by: Borys Ulanenko

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