Certificate Course in International Taxation and Transfer Pricing

Duration 10 days 20 modules · 65 contact hours
Level Intermediate Certificate on completion
Who attends International Tax Managers, Transfer Pricing Managers and others
Fee from USD 2,200 KSh 190,000 for Kenyan organisations
Where 52 cities + online See dates by city
Next start 9 Nov 2026 Course code SD-T-030

Before you join: Participants should understand basic corporate income tax concepts, financial statements and common business transactions such as sales, services, loans and royalties.

Dates & prices

Two start dates a month in every city, and live online on weekdays or weekends. Fees are per participant; classroom fees include tuition, materials, lunch and refreshments, and the certificate.

Suggest a date or city

Showing the next six months. Later dates, other cities and private deliveries for your team are available on request.

Course overview

Cross-border business models create tax exposures that cannot be managed through domestic tax rules alone. A group may earn revenue in one country, employ people in another, hold intellectual property elsewhere and finance operations from a fourth jurisdiction. Tax teams must determine where profits are taxable, whether a permanent establishment exists, how treaty benefits apply, and whether related-party prices can withstand audit. Errors can produce double taxation, interest, penalties, withholding tax leakage and disputes between tax authorities.

This certificate course develops working capability in international taxation and transfer pricing. Participants interpret tax treaty provisions, test permanent establishment risk, identify source-country taxing rights, calculate withholding tax positions and assess relief from double taxation. They apply the arm’s length principle using functional analysis, comparability analysis and accepted transfer pricing methods. The programme also addresses OECD Base Erosion and Profit Shifting measures, transfer pricing documentation, country-by-country reporting, advance pricing agreements, mutual agreement procedure and tax controversy preparation.

Teaching combines practitioner briefings with worked calculations, treaty reading, case analysis, group decisions and document review. Participants build a cross-border tax and transfer pricing file progressively through the programme, using a realistic multinational operating model involving distribution, services, financing and intellectual property. They leave with a structured analysis pack that can be adapted for tax risk reviews, transaction planning and audit preparation.

The programme suits finance, tax, legal, audit and commercial professionals who work with multinational groups, cross-border transactions or related-party arrangements. It is particularly useful for professionals moving from domestic tax work into international tax responsibilities.

What you will be able to do

  • Interpret OECD and UN Model Tax Convention articles for cross-border transactions
  • Assess permanent establishment risk using treaty tests and factual indicators
  • Calculate withholding tax, foreign tax credit and double-tax relief positions
  • Perform a functional analysis covering functions, assets and economically significant risks
  • Select and apply appropriate transfer pricing methods under OECD guidance
  • Prepare core local file, master file and country-by-country reporting content
  • Evaluate BEPS-related tax risks in financing, intellectual property and principal structures
  • Present a defensible cross-border tax and transfer pricing analysis pack

Benefits of attending

For you

  • Build confidence analysing treaty entitlement, withholding taxes and permanent establishment exposure
  • Use recognised transfer pricing methods to challenge or support related-party pricing
  • Prepare clearer documentation requests for finance, legal and operational stakeholders
  • Contribute credibly to tax authority audits, information requests and dispute discussions
  • Create a reusable cross-border tax review pack for current work responsibilities

For your organisation

  • Earlier identification of permanent establishment and withholding tax exposures
  • Better support for arm’s length pricing across services, financing and intellectual property
  • More consistent transfer pricing documentation and country-by-country reporting inputs
  • Reduced risk of double taxation through stronger treaty and relief analysis
  • Improved readiness for tax audits, mutual agreement procedures and internal reviews

Course modules

20 modules over 10 days

Participants can map the principal tax consequences of a multinational operating model.

  • Residence, source and territorial taxation principles governing cross-border income
  • Corporate structures mapped through legal entities, branches and transaction flows
  • Identify direct tax, withholding tax, indirect tax and customs touchpoints
  • Tax risk register linking transactions, jurisdictions, owners and evidence
  • Distinguishing legal form, economic substance and commercial purpose
  • Cross-border operating model used throughout the programme case

Participants can determine residence positions and assess entitlement to treaty benefits.

  • Corporate residence tests based on incorporation, management and control
  • Dual-resident entities resolved through treaty tie-breaker provisions
  • Individual residence, domicile and habitual abode concepts
  • Treaty entitlement tested against beneficial ownership and limitation provisions
  • Examine principal purpose test indicators within treaty benefit claims
  • Residence certificates and supporting evidence for treaty relief applications

Participants can interpret key treaty articles using OECD and UN Model conventions.

  • OECD Model structure and article sequence for treaty analysis
  • UN Model differences affecting source-country taxing rights
  • Apply Vienna Convention interpretation principles to treaty language
  • Business profits article analysed with linked permanent establishment provisions
  • Articles covering dividends, interest, royalties and capital gains
  • OECD Commentary used carefully when interpreting ambiguous treaty terms

Participants can assess fixed place, agency and service permanent establishment risks.

  • Fixed place permanent establishment tested through place, permanence and disposal
  • Agency permanent establishment indicators under dependent agent rules
  • Service permanent establishment clauses and day-count threshold calculations
  • Preparatory and auxiliary activities distinguished from core business functions
  • Remote workers assessed for corporate tax presence risk
  • Permanent establishment risk memo supported by operational facts

Participants can attribute profits to a permanent establishment using authorised OECD principles.

  • Article 7 business profits rule applied after permanent establishment finding
  • Authorised OECD Approach separates functions, assets and risks
  • Dealings between head office and permanent establishment identified
  • Allocate revenue and expenses using factual profit drivers
  • Internal charges examined for support, benefit and allocation basis
  • Prepare profit attribution schedule for branch operations

Participants can calculate withholding obligations and available relief from double taxation.

  • Statutory withholding taxes compared with treaty-reduced rates
  • Dividend, interest and royalty payment flows analysed separately
  • Gross-up clauses modelled for contractual withholding tax allocation
  • Foreign tax credit limitation calculated against domestic tax liability
  • Exemption and credit methods compared for double-tax relief
  • Relief-at-source and refund procedures documented with filing evidence

Participants can identify tax consequences of international employee mobility and remote work.

  • Article 15 employment income tested through 183-day conditions
  • Employer, economic employer and payroll recharge evidence assessed
  • Short-term business visitors tracked through jurisdictional day counts
  • Equity compensation allocated across vesting and work periods
  • Remote work arrangements reviewed for payroll and permanent establishment exposure
  • Shadow payroll requirements identified from host-country obligations

Participants can frame related-party transactions under the arm’s length principle.

  • Associated enterprises defined under Article 9 and domestic rules
  • Arm’s length principle compared with group-wide profit allocation
  • Controlled transactions classified as goods, services, financing or intangibles
  • Written intercompany agreements tested against actual conduct
  • Accurate delineation identifies economically relevant transaction conditions
  • Transfer pricing policy linked to value creation and evidence

Participants can perform a functional analysis that supports transfer pricing characterisation.

  • FAR analysis maps functions, assets and economically significant risks
  • Interview evidence converted into a functional analysis matrix
  • Contractual risk allocation tested against actual risk control
  • Financial capacity assessed for parties assuming material risks
  • Characterise entities as distributors, manufacturers, service providers or entrepreneurs
  • Value chain diagram links activities to profit expectations

Participants can conduct a comparability analysis and interpret benchmarking results.

  • Comparability factors assess characteristics, functions, terms and market conditions
  • Internal comparables evaluated before searching external comparable companies
  • Screening criteria selected for industry, geography and independence
  • Reject loss-making comparables using documented economic reasoning
  • Interquartile range calculated from accepted comparable company results
  • Working capital adjustments considered for distribution benchmarking

Participants can select and apply methods for tangible goods and distribution transactions.

  • Comparable uncontrolled price method applied to reliable external pricing
  • Resale price method tested for routine distributor transactions
  • Cost plus method used for contract manufacturing arrangements
  • Transactional net margin method applied using operating margin indicators
  • Profit level indicators selected from return on sales or costs
  • Method selection memo explains reliability and data limitations

Participants can evaluate service charges, benefit tests and allocation keys.

  • Benefit test distinguishes shareholder activity from chargeable group services
  • Service categories documented through deliverables, recipients and cost pools
  • Allocation keys selected using headcount, revenue or usage drivers
  • Cost base reviewed for pass-through expenses and excluded items
  • Low value-adding services approach assessed under OECD guidance
  • Management fee schedule reconciled to general ledger records

Participants can analyse arm’s length terms for cross-border financing arrangements.

  • Debt capacity assessed through cash flows, covenants and credit metrics
  • Loan delineation considers currency, term, security and repayment profile
  • Credit rating methods estimate borrower stand-alone creditworthiness
  • Comparable uncontrolled interest rates adjusted for borrower-specific factors
  • Guarantee fees assessed through benefit, risk and pricing analysis
  • Thin capitalisation and interest limitation rules incorporated into planning

Participants can assess ownership, returns and pricing for intangible-related transactions.

  • Intangibles identified through legal rights and economically valuable attributes
  • DEMPE functions determine entitlement to intangible-related returns
  • Legal ownership distinguished from control over development decisions
  • Royalty bases tested against revenue definitions and benefit received
  • Valuation approaches include income, market and cost-based methods
  • Hard-to-value intangibles considered under OECD guidance

Participants can identify BEPS-related challenges to common cross-border structures.

  • BEPS Actions linked to transfer pricing, treaties and reporting
  • Principal purpose test assessed using purpose and outcome evidence
  • Hybrid mismatch arrangements reviewed for deduction and inclusion outcomes
  • Controlled foreign company rules identify low-taxed mobile income
  • Interest limitation rules tested using fixed-ratio approaches
  • Economic substance evidence assembled for holding and finance entities

Participants can plan documentation packages that meet common multinational reporting requirements.

  • Master file content covers group structure, value chain and policies
  • Local file documents material transactions, analysis and financial results
  • Country-by-country report data reconciled to consolidated financial statements
  • Constituent entities, jurisdictions and permanent establishments mapped accurately
  • Documentation deadlines aligned with local statutory requirements
  • Evidence index connects contracts, invoices, calculations and operational records

Participants can prepare a coordinated response to transfer pricing audits and double-tax disputes.

  • Audit readiness file organises positions, evidence and responsible owners
  • Information requests triaged by relevance, confidentiality and response deadline
  • Transfer pricing adjustments analysed for primary and corresponding effects
  • Mutual agreement procedure initiated under applicable treaty provisions
  • Advance pricing agreements evaluated for suitability and resource requirements
  • Dispute chronology records facts, submissions, meetings and authority positions

Participants can identify tax and transfer pricing issues in transactions and business restructurings.

  • Acquisition due diligence identifies historical tax and documentation exposures
  • Business restructurings tested for transfer of functions, assets and risks
  • Exit charges considered when valuable activities move jurisdictions
  • Post-merger integration maps new intercompany flows and legal entities
  • Supply chain changes assessed for customs, tax and transfer pricing effects
  • Transaction tax checklist assigns issues, advisers and decision deadlines

Participants can establish practical controls for recurring international tax and transfer pricing obligations.

  • Tax control framework assigns ownership, approvals and evidence retention
  • Intercompany agreement governance aligns legal, tax and finance stakeholders
  • Quarterly monitoring tracks material changes to transaction facts
  • Tax risk register scored by likelihood, impact and control effectiveness
  • Board reporting converts technical issues into decision-focused summaries
  • Escalation protocols define when external advice or disclosure is required

Participants can build, review and present a complete cross-border tax and transfer pricing analysis pack.

  • Map legal entities, transaction flows and taxing rights
  • Assess treaty entitlement, permanent establishment and withholding tax exposure
  • Complete FAR analysis and characterise each related-party entity
  • Select pricing methods and calculate arm’s length outcome ranges
  • Draft documentation plan, evidence index and risk register
  • Present conclusions, assumptions, recommendations and implementation priorities

Exercises and examples are adapted to each cohort's sectors and roles.

What you take back to work

  1. Cross-border tax risk register template
  2. Tax treaty interpretation checklist
  3. Permanent establishment assessment matrix
  4. Transfer pricing functional analysis template
  5. Transfer pricing method selection memorandum
  6. Master file and local file evidence index

Who should attend

  • International Tax Managers — need defensible positions for group transactions and tax authority enquiries
  • Transfer Pricing Managers — need stronger treaty, permanent establishment and BEPS knowledge
  • Corporate Tax Managers — need to assess overseas operations and related-party arrangements
  • Finance Directors — need informed oversight of cross-border tax exposures and reporting
  • In-House Legal Counsel — need to identify treaty, withholding tax and dispute implications
  • Audit and Advisory Professionals — need structured methods for reviewing multinational tax positions

Skills and tools covered

Treaty interpretationPermanent establishment analysisTransfer pricing methodsFunctional analysisTax documentationCross-border dispute management

Tools and standards

OECD Model Tax Convention, UN Model Double Taxation Convention, OECD Transfer Pricing Guidelines, OECD BEPS Action Plan

How the course runs

Training methodology

The course uses short technical briefings followed by treaty reading, worked tax calculations, document review and facilitated case work. Participants analyse a multinational group’s operating model, map transaction flows and make reasoned tax and pricing decisions using supplied facts. Group exercises test alternative fact patterns, including remote sales, service centres, intercompany loans and intellectual property arrangements. Simulated audit questions and management discussions develop concise explanation of positions. Each module adds material to an individual application pack, with instructor feedback before the final presentation.

Requirements and prerequisites

Participants should understand basic corporate income tax concepts, financial statements and common business transactions such as sales, services, loans and royalties. At least one year of experience in tax, finance, accounting, audit, legal or commercial roles is recommended. Familiarity with related-party transactions is helpful but not essential. The course assumes participants can read numerical schedules and use spreadsheets for simple calculations. Prior specialist knowledge of tax treaties, OECD materials, transfer pricing methods or country-by-country reporting is not required. It is not a substitute for jurisdiction-specific legal advice or professional tax filing authority.

A typical training day

08:30 – 10:30First session
10:30 – 10:45Refreshment break
10:45 – 12:30Second session
12:30 – 13:30Lunch and networking
13:30 – 15:00Third session
15:00 – 15:15Refreshment break
15:15 – 16:30Workshop and daily review

Live online deliveries follow the same structure in East Africa Time, with shorter screen blocks and longer breaks.

What the fee includes

  • Instruction by a practitioner facilitator
  • Full course workbook and materials
  • Exercise files, templates and case studies
  • Refreshments and lunch on classroom deliveries
  • Certificate of completion
  • Post-course application plan

Frequently asked questions

You should understand basic corporate tax and financial statement concepts, and be comfortable reading transaction data. Specialist knowledge of tax treaties or transfer pricing is not required; the course starts with the core international tax architecture before moving into technical analysis.

Bring a laptop with spreadsheet software if attending in person, plus any non-confidential examples of cross-border transactions you want to consider. Course materials, case facts and templates are provided.

It is designed for tax, finance, accounting, legal, audit and advisory professionals with cross-border responsibilities. It also suits managers who oversee overseas entities, intercompany charges, foreign financing or international growth.

Domestic tax courses focus primarily on one jurisdiction’s tax rules. This programme addresses the interaction between jurisdictions, tax treaties, permanent establishments, withholding taxes, double-tax relief, transfer pricing and multinational reporting.

Participants can use the treaty checklist, permanent establishment matrix, functional analysis template and tax risk register on live business arrangements. The final analysis pack provides a practical structure for internal reviews, adviser discussions and audit preparation.

Each day runs from 08:30 to 16:30 and provides about 6.5 contact hours. The first part establishes treaty and cross-border tax analysis, while the later modules develop transfer pricing, documentation, dispute management, governance and the capstone presentation.

Questions about this course?

Ask about dates, fees, group bookings or running it for your team. Our training team replies by email.

Ask on WhatsApp info@skillsetdevelopment.com

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