Transfer Pricing Strategies Training Course

Duration 5 days 10 modules · 33 contact hours
Level Intermediate Certificate on completion
Who attends Transfer Pricing Analysts, Tax Managers and others
Fee from USD 1,100 KSh 95,000 for Kenyan organisations
Where 52 cities + online See dates by city
Next start 16 Nov 2026 Course code SD-T-041

Before you join: Participants should have basic familiarity with corporate income tax, financial statements and intercompany transactions.

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

Transfer pricing affects taxable profit allocation, customs values, withholding tax exposure and the risk of double taxation. Groups that price management services, goods, loans, royalties or contract manufacturing arrangements without clear evidence can face tax authority adjustments, penalties and lengthy audits. Finance and tax teams need to connect legal agreements, operational conduct, financial data and market evidence before setting or defending an intercompany price.

This course explains the arm’s-length principle and the practical decisions behind transfer pricing policy. Participants work through functional analysis, the OECD five comparability factors, method selection, comparable-company searches, profit level indicators, intercompany services, financial transactions and intangible property. The course also addresses OECD Transfer Pricing Guidelines, the UN Practical Manual, BEPS Action 13 documentation, Country-by-Country Reporting, audit readiness, advance pricing agreements and mutual agreement procedures.

Teaching combines focused instructor briefings with worked cases involving distributors, contract manufacturers, shared-service centres, group loans and intellectual property. Participants analyse transaction facts, select and defend methods, interpret financial data and prepare documentation evidence. They leave with a reusable transfer pricing policy outline, functional analysis template, method-selection decision model, comparables review checklist, documentation calendar and audit-response plan.

The course is suited to tax, finance, accounting, legal and internal audit professionals who support cross-border related-party transactions. It is particularly relevant for professionals moving into transfer pricing responsibilities or seeking a structured method for reviewing existing group policies.

What you will be able to do

  • Apply the arm’s-length principle to common related-party transactions
  • Conduct a functional analysis using functions, assets, risks and DEMPE evidence
  • Select and justify an appropriate transfer pricing method
  • Assess comparability using OECD five-factor analysis and financial adjustments
  • Calculate routine returns using margin indicators and comparable-company data
  • Prepare core master file, local file and Country-by-Country Reporting evidence
  • Evaluate transfer pricing risks in services, financial transactions and intangible arrangements
  • Build a practical transfer pricing governance and documentation action plan

Benefits of attending

For you

  • Build confidence selecting and explaining transfer pricing methods
  • Prepare stronger evidence for local file and audit requests
  • Interpret comparable-company analyses and margin calculations critically
  • Contribute effectively to intercompany policy and agreement reviews
  • Develop a documented plan for managing transfer pricing responsibilities

For your organisation

  • Reduce unsupported intercompany pricing and documentation gaps
  • Improve consistency between legal agreements, operational conduct and financial results
  • Strengthen preparation for tax audits, information requests and penalty reviews
  • Create clearer ownership for transfer pricing data, approvals and monitoring
  • Support more defensible cross-border pricing decisions and tax provision estimates

Course modules

10 modules over 5 days

Participants can identify controlled transactions and explain the arm’s-length principle using group business facts.

  • Related-party transactions mapped through legal entities, functions, assets and risks
  • Arm’s-length principle under OECD Guidelines and United Nations Manual
  • Tax residence, permanent establishments and controlled transactions distinguished clearly
  • Commercial rationale tested against contractual terms and actual conduct
  • Group value chains traced from procurement through sales and services
  • Jurisdictional tax-rate differences linked to transfer pricing risk indicators

Participants can document functions, assets and risks to establish each party’s economic profile.

  • Functional analysis documents economically significant functions, assets and risk control
  • DEMPE framework identifies development, enhancement, maintenance, protection and exploitation activities
  • Contractual risk allocation compared with decision-making capacity and financial capability
  • Intercompany agreements tested against conduct, authority and risk mitigation
  • Value-chain interviews gather evidence from finance, operations and legal teams
  • Risk-control matrices separate formal ownership from substantive control

Participants can select a transfer pricing method and identify an appropriate tested party.

  • Comparable uncontrolled price method assesses closely matched third-party transactions
  • Resale price method tests distributors using gross margin comparables
  • Cost plus method prices routine manufacturing and service arrangements
  • Transactional net margin method selects appropriate profit level indicators
  • Profit split method addresses integrated operations and unique contributions
  • Method selection follows comparability, data reliability and transaction economics
  • Berry ratios and return-on-sales measures matched to tested parties

Participants can assess comparability and evaluate comparable-company benchmarking results.

  • Five comparability factors structure controlled and uncontrolled transaction analysis
  • Comparable searches screen independent companies using industry codes and financial filters
  • Quantitative filters remove loss-makers, start-ups and atypical business models
  • Working-capital adjustments improve margin comparability between tested parties
  • Interquartile ranges derived from accepted comparable-company financial results
  • Multi-year data distinguishes cyclical performance from persistent outliers
  • Documented rejection reasons support defensible comparable selection during audit

Participants can analyse common intercompany arrangements and identify their pricing drivers.

  • Limited-risk distributor models distinguish routine returns from entrepreneurial residual profit
  • Contract manufacturing arrangements allocate returns according to functions and risk
  • Management-service charges apply benefit tests, allocation keys and mark-ups
  • Central procurement arrangements test purchasing contributions and volume discounts
  • Financial transactions assess credit ratings, loan terms and arm’s-length interest
  • Cash-pool pricing separates deposit, borrowing and coordination functions
  • Guarantee fees assessed through yield approaches and expected-loss analysis

Participants can assess intangible-related returns using DEMPE analysis and supporting evidence.

  • OECD DEMPE analysis links intangible returns to people functions and control
  • Legal ownership distinguished from economic entitlement to intangible-related income
  • Hard-to-value intangibles assessed using ex ante valuation assumptions
  • Royalty rates benchmarked through comparable licence agreements and valuation methods
  • Cost contribution arrangements tested for participants’ expected benefits and contributions
  • Valuation techniques compare income, market and cost-based intangible evidence

Participants can plan and assemble documentation that supports transfer pricing positions.

  • Master file content connects group structure, value creation and policies
  • Local file substantiates material transactions, methods, comparables and financial results
  • Country-by-Country Report data reconciled to statutory accounts and tax returns
  • BEPS Action 13 thresholds, deadlines and filing mechanisms identified
  • Contemporaneous documentation calendars assign owners, evidence and approval dates
  • Audit-ready files cross-reference agreements, invoices, calculations and statutory accounts
  • Documentation narratives align legal contracts with actual business conduct

Participants can assess controversy risk and organise an effective response to tax authority scrutiny.

  • Transfer pricing risk assessment ranks transactions by materiality, complexity and evidence
  • Tax authority information requests answered through controlled evidence protocols
  • Audit defence files organise positions, comparables, calculations and interview records
  • Advance pricing agreements evaluate certainty, cost and administrative commitments
  • Mutual agreement procedure addresses double taxation under treaty provisions
  • Penalty regimes linked to documentation quality, filing discipline and governance
  • Controversy response plans define escalation, privilege and stakeholder communications

Participants can reconcile financial data to transfer pricing results and manage year-end adjustments.

  • Segmented profit-and-loss statements align tested-party results with controlled transactions
  • Trial-balance data reconciled to transfer pricing calculations and statutory accounts
  • Operating expense classifications distinguish pass-through costs from value-adding costs
  • True-up mechanisms calculate year-end adjustments and indirect tax consequences
  • Foreign-exchange effects separated from operating performance in margin analysis
  • Intercompany invoicing controls preserve pricing evidence and accounting consistency

Participants can create a governance plan for maintaining transfer pricing policies and evidence.

  • Transfer pricing policies translate method conclusions into executable operating procedures
  • RACI matrices assign finance, tax, legal and business responsibilities
  • Quarterly monitoring compares actual margins against policy target ranges
  • Material transaction changes trigger method review and documentation updates
  • Board reporting presents exposures, decisions, remediation owners and milestones
  • Implementation plans sequence data, agreements, pricing controls and review dates

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

What you take back to work

  1. Transfer pricing policy outline
  2. Functional analysis template
  3. Method-selection decision model
  4. Comparables review checklist
  5. BEPS Action 13 documentation calendar
  6. Transfer pricing audit-response plan

Who should attend

  • Transfer Pricing Analysts — need a structured method for analysing and documenting related-party transactions
  • Tax Managers — need to oversee policy, compliance deadlines and controversy exposure
  • Financial Controllers — need to reconcile pricing policies with management and statutory accounts
  • Group Accountants — need to process intercompany charges and year-end pricing adjustments accurately
  • Corporate Tax Advisers — need to advise business teams on defensible arm’s-length arrangements
  • Internal Auditors — need to review pricing controls, evidence trails and tax risk indicators

Skills and tools covered

Functional analysisMethod selectionComparability analysisDocumentation planningIntercompany pricingAudit defence

Tools and standards

OECD Transfer Pricing Guidelines, UN Practical Manual on Transfer Pricing, BEPS Action 13, DEMPE framework

How the course runs

Training methodology

The course uses short technical briefings followed by instructor-led analysis of realistic group transactions. Participants work with cases covering distribution, manufacturing, services, financing and intangibles, using financial extracts, agreements and operational facts. Small-group tasks focus on functional analysis, method selection, comparables review and documentation decisions. Facilitated simulations examine audit information requests and internal policy approvals. Each participant develops an application plan for improving a current or anticipated transfer pricing process.

Requirements and prerequisites

Participants should have basic familiarity with corporate income tax, financial statements and intercompany transactions. Experience in tax, accounting, finance, audit, legal or treasury roles is helpful, particularly where participants support multinational groups. Participants should be comfortable reading profit-and-loss statements and discussing business operations. Prior transfer pricing training is not required. Advanced valuation skills, econometric modelling, legal drafting expertise and prior experience with tax authority audits are not required; the course explains how these specialist inputs fit within a transfer pricing project.

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 concepts, financial statements and intercompany transactions. No previous transfer pricing course or specialist valuation experience is required.

Bring a laptop if possible, along with non-confidential examples of transactions, policies or documentation challenges from your work. Course materials and case data are provided.

It is designed for tax, finance, accounting, legal, treasury and internal audit professionals supporting multinational or cross-border groups. It suits professionals with operational responsibility as well as advisers reviewing client arrangements.

Corporate tax courses focus on taxable income, tax computations and filing obligations. This course concentrates on pricing and documenting transactions between related entities under the arm’s-length principle.

You can use the functional analysis template to review a transaction, assess whether the selected method fits the facts and identify missing documentation. The governance plan also helps assign owners for data, approvals and periodic monitoring.

Training runs from 08:30 to 16:30 each day, providing about 6.5 contact hours daily. The five days progress from foundations and functional analysis through methods, documentation, controversy management and implementation planning.

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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