Postgraduate Diploma in Transfer Pricing

This award builds on the knowledge gained from Module 1 and further aims to ensure a student can identify the different Transfer Pricing methods for controlled transactions, identify a comparability analysis and determine an arm’s length charge for Intra-Group Services. The learning explores the working, application and calculations required for each method. The module also covers the documentation requirements per the OECD guidelines and specific points relating to the BEPS Action list, risk management and dispute resolution.

On successfully completing this module, you will be able to:

• Apply the rules of Articles 7, 9, 10-12 of the OECD and UN Model Tax Convention to prevent the improper use of tax treaties.
• Interpret and apply Transfer Pricing Case Law considering ethical issues to assess the legality of certain tax planning measures.
• Apply Transfer Pricing policies in line with internationally recognised principles to prevent double taxation and stimulate international trade.
• Analyse the Arm’s length principle for a specific transaction to establish acceptable transfer prices.
• Prepare a functional analysis for controlled transactions to delineate such transactions.
• Select the most appropriate Transfer Pricing method during a specific transaction and justify why this method is indeed the most appropriate.
• Carry out the various steps required to perform a Functional Analysis to determine whether controlled and uncontrolled transactions or entities are comparable.