Tax and Legal

Transfer Pricing and International Tax Structuring

Transfer pricing exposure is created by ordinary operating decisions such as where a service is performed or which entity carries a loan, and it is discovered years later by an authority applying hindsight. This course covers managing it deliberately. Delegates work through the arm's length principle and what it requires in practice, and functional analysis, which is the step that determines everything after it. Comparability and the difficulty of finding comparables in African markets are addressed honestly. The transfer pricing methods are covered on when each applies. Intra group services, management fees and the benefit test follow, since these are the most commonly challenged. Intra group financing and thin capitalisation are addressed. Documentation requirements including master file, local file and country by country reporting are covered. The course closes on audit defence, on advance pricing arrangements and on structures that will not survive scrutiny.