In a context where international transfer pricing regulations are becoming stricter (BEPS 2.0, digitalisation of trade, Country-by-Country Reporting) and where tax authorities are increasing their tax audits, companies are facing an increased risk of tax adjustments and greater compliance challenges. Optimal management of intra-group subsidiaries and robust documentation are now essential levers for securing tax positions while maintaining competitiveness.
This training course enables participants to master recent developments in transfer pricing and identify opportunities for optimisation in a complex regulatory environment.
During this advanced training session, you will explore:
Arm's length principles and methods (CUP, RPM, TNMM, etc.) based on the latest OECD guidelines;
The creation and defence of compliant documentation (Master File, Local File, CbC Reporting);
Practical cases, comparable analyses, adjustment exercises and tax audit simulations.
After the training, participants will be able to:
Evaluate and justify transfer pricing policies;
Structure and update intra-group documentation;
Anticipate and respond to requests from tax authorities;
Identify and exploit tax optimisation opportunities.
Objectifs
- Understanding the key economic, financial, tax and legal aspects relating to the pricing of business transactions between affiliated companies.
- Learning how to face the challenges related to transfer pricing, best practices and pragmatic approaches.
Compétences acquises
Following the training, you will be able to analyse the main issues related to transfer pricing.
