The Advanced Transfer Pricing course has been designed for students and practitioners who already have basic knowledge in the field of transfer pricing and are interested to further their knowledge and understanding in this area. It includes subjects such as: location savings and transfer pricing adjustments, the application of the profit-split method, the application of evaluation techniques to intangibles, supply chain restructuring, and selected issues on financial services. These topics are dealt through an in-depth analysis from both a theoretical and a practical perspective and involve current business models applied by multinational enterprises (e.g., matrix-type organizational structures, hub structures, co-entrepreneurial structures). The course also deals with the particularities of different industries (such as: fashion, fast-moving consumer goods, pharmaceutical) with references to industry analysis, functional analysis, distribution policy, intercompany services and benchmarking analysis. In addition to the lectures, the course features workshops in which real-life case studies are analyzed. For example, there is a workshop dealing with database search where the various steps of such a search (e.g., NACE Codes selection for defining the initial sample, timing of origin of comparable data, application of quantitative screening criteria such as independence and turnover threshold, web and financial statements analysis) are examined and discussed in detail through an analysis of the issues based on examples from tax practice. Also the interaction between transfer pricing and indirect taxes (i.e., customs and VAT) is dealt with addressed in a specific section.
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