Transfer Pricing Fundamentals  

In today's supply chains, borders are constantly being crossed with respect to the sales of goods and the provision of services. No company no matter how big or how small is immune to engaging in cross-border transactions. Whether it is a domestic manufacturer, wholesaler, retailer, or service provider, somewhere in its business a cross-border transaction can be found.

Where the cross-border transaction is with a related party, arms-length transfer pricing principles will apply to determine the profit allocation to the jurisdictions where the transaction is deemed to occur.

This course focuses on the development of in-depth knowledge, skill, and application of transfer pricing. It is most appropriate for the professional with mastery of transfer pricing who may be a seasoned professional within an organization but also may be appropriate for other professionals with certain specialized knowledge in taxation.

In the U.S., transfer pricing can occur domestically within interstate commerce between the states, or internationally, between the U.S. and foreign countries. This course will focus on the U.S. transfer pricing rules found principally under the Section 482 income tax regulations including two of the more important transfer pricing developments, T.D. 9738 and T.D. 9773.

By proceeding to the examination, you acknowledge and confirm that you have completed the required coursework.