OECD Transfer Pricing Guidelines Application Training Course

Course overview

Multinational groups must set and defend prices for intercompany goods, services, financing, intellectual property and restructurings under rules that are interpreted differently by tax authorities. Finance, tax and transfer pricing professionals need more than familiarity with the arm’s-length principle: they need a repeatable way to identify controlled transactions, analyse functions and risks, select an appropriate OECD method, establish comparables and document conclusions that can withstand internal review, audit queries and potential dispute resolution.

This five-day OECD Transfer Pricing Guidelines Application Training Course translates the OECD Transfer Pricing Guidelines into practical decision-making steps. Participants work through the comparability analysis, functional analysis and risk-control framework; apply the CUP, resale price, cost plus, TNMM and profit split methods; assess tested-party selection and profit level indicators; and address common transactions involving management services, loans, guarantees, royalties and intangible assets. The course also examines BEPS Actions 8–10 and 13, local-file evidence, master-file content and country-by-country reporting obligations.

Teaching combines focused instructor-led explanation with worked calculations, annotated documentation examples and a connected multinational case study. Participants use a structured transaction-review workbook to prepare a functional analysis, method-selection rationale, benchmarking approach and local-file evidence plan. They leave with an OECD Guidelines application pack: practical templates, calculation models, review checklists and a 90-day action plan for improving transfer pricing processes or supporting a live assignment.

The programme suits professionals who contribute to intercompany pricing decisions, transfer pricing documentation, tax provision support or audit responses. It is equally valuable to managers seeking a consistent internal approach before commissioning external benchmarking studies or responding to tax authority information requests.

Course objectives

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

• Identify controlled transactions and map them to the OECD arm’s-length principle
• Perform a functions, assets and risks analysis using an interview-led FAR template
• Apply the five OECD transfer pricing methods to fact patterns and select a defensible method
• Construct a comparability analysis covering contractual terms, economic circumstances and business strategies
• Calculate and interpret mark-ups, operating margins and profit level indicators for TNMM testing
• Assess DEMPE functions, risk control and remuneration issues for intangible-property arrangements
• Prepare a method-selection memorandum and local-file evidence checklist aligned to BEPS Action 13
• Develop an audit-ready transfer pricing application plan for a selected intercompany transaction

Benefits of attending

Target competencies

Who should attend

• Transfer Pricing Analysts — who need to apply OECD methods in documentation, benchmarking and transaction reviews
• Corporate Tax Managers — who oversee group tax positions and need to challenge transfer pricing conclusions
• Finance Managers — who set or monitor intercompany charges, service allocations and operating margins
• Tax Accountants — who support tax provisions, local-file preparation and audit information requests
• International Tax Advisers — who need a structured framework for analysing cross-border related-party dealings
• Internal Audit and Compliance Managers — who review governance, evidence trails and controls around intercompany pricing

Requirements and prerequisites

Participants should understand basic financial statements, including revenue, operating costs, gross margin and operating profit, and should be comfortable reading a simple profit and loss account. Familiarity with related-party transactions, corporate tax concepts or intercompany agreements is helpful but not essential. Participants should be able to use Microsoft Excel for simple formulas, filters and tables; no specialist transfer pricing database skills are assumed. This is a foundation-to-intermediate course: complete newcomers can attend, but should expect to work with financial calculations, transaction narratives and case-study documentation from the first day.

Training methodology

The programme uses short instructor-led sessions to establish the relevant OECD framework, followed by calculations, document review and facilitated case analysis. Working in small groups, participants analyse a multinational group’s value chain, interview notes, agreements and financial data; then build a FAR profile, compare method options and test a selected transaction in Excel. Instructor feedback focuses on the quality of evidence and reasoning, not just the numerical result. On day five, each participant converts the case approach into a transaction-specific action plan for their own organisation or client portfolio.

Course outline

Day 1: OECD framework and transaction scoping

• Purpose and structure of the OECD Transfer Pricing Guidelines
• Arm’s-length principle under OECD Model Tax Convention Article 9
• Controlled transactions and related-party relationship tests
• Mapping group value chains and intercompany transaction flows
• Accurate delineation of the actual commercial transaction
• Contractual terms, written agreements and conduct evidence
• Introduction to the functions, assets and risks framework

Workshop: Participants map a case-study group’s legal entities and intercompany flows, producing a transaction inventory and initial risk flags.

Day 2: Functional analysis and comparability

• Functions, assets and risks interview techniques
• Risk assumption versus risk control under the OECD framework
• Financial capacity to assume and manage risk
• Comparability factors and their evidential sources
• Characterising entities as limited-risk distributors, manufacturers or service providers
• Business strategies, market conditions and economic circumstances
• Comparability adjustments and reliability assessment

Workshop: Teams build a FAR matrix for a distributor and contract manufacturer, then produce a written entity-characterisation conclusion.

Day 3: Applying OECD pricing methods

• Comparable uncontrolled price method and internal comparables
• Resale price method for distribution transactions
• Cost plus method for manufacturing and intra-group services
• Transactional net margin method and tested-party selection
• Profit level indicators including EBIT margin, Berry ratio and return on costs
• Transactional profit split method and contribution analysis
• Method selection hierarchy, reliability and rejection rationale

Workshop: Participants evaluate five method options for a cross-border distribution arrangement and produce a method-selection memorandum with supporting calculations.

Day 4: Complex transactions, intangibles and financial dealings

• DEMPE analysis for marketing and technology intangibles
• Legal ownership and economic returns from intangibles
• Intra-group service benefit test and shareholder activity exclusions
• Service cost allocation keys and appropriate mark-ups
• OECD approach to intercompany loans and credit ratings
• Financial guarantees, cash pooling and treasury functions
• Business restructurings, exit charges and post-restructuring remuneration

Workshop: Groups analyse a centralised IP and financing model, producing a DEMPE map and a list of pricing and documentation issues.

Day 5: Documentation, controversy readiness and implementation

• BEPS Action 13 master file, local file and country-by-country report
• Local-file transaction narratives and financial information requirements
• Benchmarking study inputs, screening criteria and range interpretation
• Year-end testing, true-up mechanisms and intercompany invoicing controls
• Audit-ready evidence files and tax authority information requests
• Corresponding adjustments, mutual agreement procedure and dispute prevention
• Transfer pricing governance calendar and implementation ownership

Workshop: Participants assemble an OECD Guidelines application pack for the case company, including a local-file evidence checklist, calculation review and 90-day implementation plan.

Tools & standards covered

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2022), OECD BEPS Action 13 Transfer Pricing Documentation standard, OECD Model Tax Convention Article 9, Microsoft Excel

A typical training day

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

What the fee includes

How you can take this course

Certification

Participants who complete the full five days receive the Skillset Development Certificate of Completion, stating the course title, course code, dates and delivery format — suitable for professional-development records and employer reimbursement.

Frequently asked questions