The Postgraduate Certificate in Transfer Pricing is an introductory course in the study of Transfer Pricing. It is a 6-month programme designed for people who merely want to obtain an overview of the subject. It is ideal for those who need to understand the basic principles of transfer pricing, but will not necessarily be a technician in the field.
The programme is covered in 2 modules:
- The aim of this module is to highlight the legal framework that covers Transfer Pricing. Transfer Pricing touches multinational corporations, working in multiple jurisdictions. This module will provide the student with an overview of the tools needed to assess the legal environment of a specific jurisdiction when applying the transfer pricing principles. This is a very broad module, however, it lays the foundation for the rest of the course. The appreciation of operating within an ethical framework and specifically within the Transfer Pricing environment is discussed with the students.
- The module also covers the very important Arm’s Length Principle and Functional Analysis, laying the further groundwork for the rest of the course.
- The “Arm’s-Length Principle” of transfer pricing states that the amount charged by one related party to another for a given product must be the same as if the parties were not related. An arm’s-length price for a transaction is therefore what the price of that transaction would be on the open market.
- The functional analysis is used for transfer pricing purposes. It analyzes the functions performed (taking into account assets used and risks assumed) by associated enterprises in a transaction.
- The aim of this module is to ensure a student can identify the different TP methods for controlled transactions, identify a comparability analysis and determine an arm’s length charge for Intra-Group Services.
- The student will fully understand how each method works, the specific conditions for a method to be applied and be able to perform the calculations required for each method.
- The module explains the documentation requirements per the OECD guidelines and specific points relating to the BEPS Action list. The concept of risk management is explained to the student. Key management implications relating to risk management is discussed with the student.
- The concept of dispute resolution is explained to the student, specifically the procedures of MAP’s, APA’s and corresponding adjustments.
- As in module 1, the student is also provided with guidance relating to Ethics within the documentation, risk management and dispute resolution themes.
Who will benefit from this programme?
The structure of the programme is both theory and practice-oriented, and it is designed in a manner to enrich your advisory and consulting skills. Transfer Pricing is a complex field, and it is essential you get a thorough working knowledge of the OECD and UN Transfer Pricing Guidelines, with the additional reading requirements given to you. The lectures are designed to unpack the complexities of transfer pricing with practical examples enabling you to apply this knowledge to your professional practice.
People who would most benefit from this programme are:
- Financial Directors
- Financial Managers
- Tax Accountants
- Tax Layers
- Group Tax Managers
- Tax Managers
- Corporate Financial Consultants/ Advisors
- Entry to mid-level tax employees at MNE’s or Revenue Services
- Revenue Service Officials
By successfully completing all the assessments in modules 1 and 2 the candidate has the to opportunity complete a further 2 modulus (roughly the same length) to obtain the Postgraduate Diploma in Transfer Pricing.
The next intake will take place after final validation by Middlesex University. It is anticipated to be in the second quarter of 2022.