ΠΕΡΙΓΡΑΦΗ

International taxation and transfer pricing have become increasingly interconnected as organisations expand across borders, adopt complex operating models, and align with global regulatory expectations.

Understanding how tax systems operate, how double tax treaties apply, and how the arm’s-length principle shapes intra-group pricing is essential for managing financial risk, ensuring compliance, and supporting strategic decision-making.

This comprehensive programme provides an in-depth exploration of advanced tax principles and OECD-based transfer pricing frameworks, taught first as standalone subjects and then merged to demonstrate how they interact in real-world business environments.

Participants will learn to analyse cross-border transactions, identify risks, interpret treaties, determine permanent establishment exposure, perform functional and risk analyses, apply transfer pricing methods, and prepare documentation.

Through practical examples, case studies, and integrated exercises, the programme will equip participants with the technical and practical skills required to navigate modern tax and TP requirements with confidence.

ΣΚΟΠΟΣ ΣΕΜΙΝΑΡΙΟΥ

By the end of the programme, participants will be able to:

• Explain core concepts of domestic and international taxation
• Analyse residence, source rules, and permanent establishment exposure
• Interpret double tax treaties using the OECD Model Convention
• Identify cases of double taxation and methods of elimination
• Understand anti-avoidance regimes (GAAR, SAAR, CFC, ATAD, BEPS)
• Explain the arm’s-length principle and OECD TP Guidelines
• Conduct functional, asset, and risk (FAR) analysis
• Select and apply appropriate transfer pricing methods
• Evaluate tax and TP implications of cross-border intra-group transactions
• Integrate tax and TP concepts to assess real business scenarios and risks
• Strengthen internal compliance, documentation, and governance frameworks

ΣΕ ΠΟΙΟΥΣ ΑΠΕΥΘΥΝΕΤΑΙ

This programme is suitable for professionals from all industries, including:

• CFOs, Finance Directors & Controllers
• Tax Managers & Consultants
• Accountants & Finance Officers
• Internal Auditors and Risk Officers
• Compliance Professionals
• Legal & Corporate Services Professionals
• CEOs, Business Owners & Senior Executives
• Anyone involved in cross-border transactions or intra-group pricing

ΠΕΡΙΣΣΟΤΕΡΕΣ ΠΛΗΡΟΦΟΡΙΕΣ

Training Outline

Part A: Advanced Principles of Taxation

 Introduction to International Taxation

• Purpose and evolution of international tax rules
• Interaction of domestic and foreign tax systems
• Key definitions and foundational concepts

Residence & Source Principles

• Corporate and individual residence rules
• Source-based jurisdiction
• Practical examples across industries

Permanent Establishment (PE)

• Definition under OECD Model
• Fixed place PE, agency PE, digital PE
• Case studies and practical implications

Double Tax Treaties

• Purpose and structure of treaties
• OECD vs UN Models
• Treaty interpretation principles
• Application to different income types

Double Taxation & Elimination Methods

• Identifying situations of double taxation
• Exemption and credit methods
• Practical examples

Anti-Avoidance Rules

• Distinction between tax evasion and avoidance
• GAAR, SAAR, TAAR
• CFC rules, hybrid mismatches, interest limitations
• ATAD and BEPS developments

Tax Case Studies

• Cross-border business scenarios
• PE identification
• Treaty application

Part B:Transfer Pricing

Introduction to Transfer Pricing

• Purpose of TP and global regulatory framework
• OECD Transfer Pricing Guidelines
• The arm’s-length principle

Functional, Asset & Risk (FAR) Analysis

• Identifying functions performed
• Risk ownership and control
• Intangibles and value creation
• Examples from multiple industries

Transfer Pricing Methods

• CUP, RPM, Cost Plus, TNMM, Profit Split
• Method selection criteria
• Practical application exercises

Intra-Group Transactions

• Intercompany services and cost allocation
• Loans, guarantees, and financial transactions
• Licensing and IP-related arrangements
• Goods and supply chain structures

Transfer Pricing Documentation

• Master File
• Local File
• Country-by-Country Reporting (CbCR)
• Benchmarking studies
• Internal controls

TP Case Studies

• Selecting TP methods
• Assessing comparability
• Real-world examples

PART C: How Tax & Transfer Pricing Merge

Interaction Between Tax & TP

• Why TP cannot be assessed without tax principles
• Alignment of PE analysis, treaty interpretation, and pricing outcomes
• Combined effect of BEPS measures

Holistic Evaluation of Cross-Border Transactions

• A unified approach to tax + TP analysis
• PE creation through intra-group arrangements
• Misalignment risks and regulatory scrutiny

Developing Integrated Policies & Controls

• Governance expectations
• Documentation strategies
• Internal review frameworks

Full Integrated Case Study

• Analyse residence, source, and PE implications
• Apply treaty provisions
• Select TP methods
• Prepare key documentation elements
• Identify combined tax and TP risks

Discussion & Q&A

Training Style

The programme uses a blended approach of structured lectures, practical examples, interactive discussions, and real-life case studies.

Participants progressively build technical understanding and apply concepts through scenario analysis and integrated exercises, ensuring both theoretical knowledge and practical, workplace-ready skills.

CPD Recognition

This programme may be approved for up to 14 CPD units in Accounting and Auditing. Eligibility criteria and CPD Units are verified directly by your association, regulator or other bodies which you hold membership.