Tax and LegalTransfer Pricing and International Tax Structuring
As African tax administrations sharpen their focus on base erosion and profit shifting, multinational groups need staff who understand both the arm's length principle and the practical documentation demanded by local revenue authorities. This course walks participants through OECD transfer pricing methods, the preparation of local and master files, and the specific documentation thresholds applied in jurisdictions across the region. It closes with a session on structuring cross border financing, royalty and management fee arrangements defensibly.
Course objectives
- Apply the five OECD transfer pricing methods to select and justify the most appropriate method for a given intercompany transaction
- Prepare a compliant local file and functional analysis for related party transactions
- Benchmark intercompany pricing using comparable company analysis and interpret benchmarking study results
- Structure cross border management fees, royalties and intercompany financing to withstand revenue authority challenge
- Anticipate and respond to transfer pricing audits and mutual agreement procedure requests
Who should attend
- Group tax managers of multinational and regional businesses
- Finance directors of companies with related party transactions
- Tax advisors and transfer pricing specialists
- Treasury managers structuring intercompany financing
- Revenue authority officials working on transfer pricing desks
Course outline
- 01The arm's length principle and the OECD transfer pricing guidelines
- 02Functional, asset and risk analysis for related party transactions
- 03Transfer pricing methods and selecting the most appropriate method
- 04Preparing local files, master files and country by country reporting
- 05Structuring intercompany financing, royalties and management fees
- 06Managing transfer pricing audits, adjustments and dispute resolution mechanisms
Scheduled sessions
| Dates | Venue | Format | Price | Register |
|---|---|---|---|---|
| 9 to 11 September 2026 | Victoria Falls, Zimbabwe | Classroom | R11,995 per delegate | Register Now |
| 10 to 12 July 2027 | Cape Town, South Africa | Classroom | R11,995 per delegate | Register Now |
| 22 to 24 July 2027 | Gaborone, Botswana | Classroom | R11,995 per delegate | Register Now |