Transfer Pricing: Principles and Documentation (AF-061) Training Course

Transfer Pricing: Principles and Documentation

Multinational groups constantly trade goods, services, financing and intellectual property between their own companies in different countries. The prices used in these…

5 daysClassroom or online

49Upcoming dates

12Cities

£2,250Fees from

Course overview

Introduction

Multinational groups constantly trade goods, services, financing and intellectual property between their own companies in different countries. The prices used in these intra-group transactions determine where profits are taxed, and tax authorities worldwide now scrutinise them closely.

This Transfer Pricing training course explains the arm's length principle and the internationally recognised methods used to price intra-group transactions. Participants learn how to carry out functional analysis, select and apply the most appropriate method, use comparables and benchmarking, and prepare the documentation that tax authorities expect.

The course also covers specific transaction types such as services, intangibles and financing, the management of transfer pricing audits and disputes, and the design of a sustainable transfer pricing policy that aligns tax compliance with business operations.

Course Objectives

By the end of this training course, participants will be able to:

Explain the arm's length principle and its role in international taxation
Conduct functional analysis of functions performed, assets used and risks assumed
Select and apply traditional and profit-based transfer pricing methods
Understand comparability analysis and benchmarking studies
Price intra-group services, intangibles and financing transactions
Prepare master file, local file and related documentation
Manage transfer pricing audits, adjustments and dispute resolution options
Design and implement a practical group transfer pricing policy

Target Audience

This training course is suitable for a wide range of professionals, including:

Tax managers and tax advisors
Finance directors and group controllers of multinational companies
Accountants preparing intercompany transactions
Internal auditors and compliance professionals
Tax authority officials
Legal advisors supporting cross-border groups
Business managers involved in supply chain and pricing decisions

Training Methodology

Participants learn through structured explanations, worked numerical examples and group case studies based on realistic multinational groups. Exercises cover functional analysis interviews, method selection, simplified benchmarking and documentation drafting, helping participants connect technical rules with practical business decisions.

Target Competencies

Arm's length analysis
Functional analysis
Transfer pricing method selection
Transfer pricing documentation
Tax risk management
Intercompany policy design

Course outline

1Day One: Transfer Pricing Fundamentals

Why Transfer Pricing Matters: Tax, financial reporting and business impacts
The Arm's Length Principle: International guidance and interpretation
Related Parties and Controlled Transactions: Scope and definitions
The Global Tax Environment: Base erosion concerns and increased transparency
Penalties and Reputational Risk: Consequences of non-compliance
Mapping Intercompany Flows: Goods, services, intangibles and finance
Case Study: Mapping the intercompany transactions of a multinational group

2Day Two: Functional and Comparability Analysis

Functional Analysis: Functions, assets and risks
Characterising Entities: Distributors, manufacturers, service providers and principals
Risk Control and Financial Capacity: Allocating risk correctly
Comparability Factors: Contract terms, economic circumstances and business strategies
Searching for Comparables: Databases, screening and adjustments
Interquartile Ranges and Year-End Adjustments: Applying results
Practical Exercise: Conducting a functional analysis interview and characterisation

3Day Three: Transfer Pricing Methods

Comparable Uncontrolled Price Method: Application and limitations
Resale Price and Cost Plus Methods: Gross margin approaches
Transactional Net Margin Method: Profit level indicators and tested parties
Profit Split Method: Integrated operations and unique contributions
Selecting the Most Appropriate Method: Practical decision criteria
Applying Methods in Practice: Calculations and documentation of choices
Workshop: Selecting and applying methods to sample transactions

4Day Four: Specific Transactions

Intra-Group Services: Benefit test, cost pools and mark-ups
Low Value-Adding Services: Simplified approaches
Intangibles: Ownership, development, enhancement and exploitation
Royalties and Licences: Pricing intellectual property
Financial Transactions: Intercompany loans, guarantees and cash pooling
Business Restructurings: Transfers of functions and risks
Case Study: Pricing services and a loan within a regional group

5Day Five: Documentation, Audits and Policy

Documentation Requirements: Master file, local file and country-by-country reporting
Writing Robust Documentation: Structure, evidence and consistency
Managing Tax Audits: Preparation, information requests and negotiation
Dispute Resolution: Mutual agreement procedures and advance pricing agreements
Operational Transfer Pricing: Implementing policies in ERP and accounting systems
Group Policy Design: Governance, monitoring and periodic review
Final Exercise: Preparing a transfer pricing documentation outline

Frequently asked questions

How long is the Transfer Pricing: Principles and Documentation course?

The course runs over 5 days of classroom training, usually Monday to Friday.

When is the next Transfer Pricing: Principles and Documentation course?

The next public date is 7 - 11 Dec 2026 in Barcelona. There are 49 upcoming dates in total.

Where is this course held?

Upcoming sessions run in Barcelona, Frankfurt, London, Istanbul, Kuala Lumpur, Madrid, Munich, Paris, Vienna, Amsterdam, Dubai, Geneva.

Can I take Transfer Pricing: Principles and Documentation online?

Yes. Every date can also be joined live online in a virtual classroom with the trainer, for £1,280 per participant. Choose "Live online" in the dates table when you register.

How much does the course cost?

Fees start from £2,250 per delegate, depending on the city. Fees include tuition and course materials.

Do participants receive a certificate?

Yes. Delegates who complete the course receive a London Leadership Management Innovation certificate of completion.

Can this course be delivered in-house for our team?

Yes. LLMI can tailor and deliver this course privately for your organisation at your premises or in one of our training cities.

Course information last updated 14 November 2026.

Transfer Pricing: Principles and Documentation

Course overview

Introduction

Course Objectives

Target Audience

Training Methodology

Target Competencies

Course outline

Dates and fees

Frequently asked questions

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