Transfer Pricing Postgraduate Diploma

PG-Dip Transfer Pricing – What You Will Study

The Postgraduate Diploma includes Stage 1 (building the foundational knowledge of Transfer Pricing) and Stage 2. Stage 1 is dealt with on the PG-Cert page.

Stage 2 builds on the different Transfer Pricing methods for controlled transactions, identifies a comparability analysis and determines 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.

Stage 1 + Stage 2

Exit Qualification: PG-Diploma, or progress to Stage 3 for Masters (MSc)

This award consists of 2 Stages. For the Postgraduate Diploma award Stage 1 & Stage 2 must be completed, consisting of 120 credits in total.

Each stage contains two modules:
- Stage 1 – TP Legal Framework & TP Methods and Compliance, with 30 credits awarded per module.
- Stage 2 (detailed below) – Sharing Corporate Resources & Specialised Areas, with 30 credits awarded per module.
The learning will address important issues within the sector, drawing on key points, to ensure you gain a thorough understanding of the topics.
Students must complete and successfully pass the assigned coursework assessments and the final exam at the end of each stage to claim their award.
Pre-recorded academic lectures will be released each week, accompanied with the prescribed reading, any additional reading and/or research, as required. Directed reading will relate to provided case law, and will also include reading from legislation, books, articles, academic and professional journals.
The learning from the lectures will be emphasised with an array of case studies, practice examples and resources, to challenge thinking in a practical context. Engaging activities on the discussion forum, the use of quizzes, polls and other forum built-in activity will further validate the learning objectives.
Each main topic will end with a live-online tutorial, conducted by the lecturers. The tutorials are designed to be interactive, providing students with the opportunity to ask questions and to consider issues from different perspectives.

AIMS OF THE PROGRAMME

STAGE 1

Module 1 (TP Legal Framework)
Module 2 (TP Methods and Compliance)

Click here to view Stage 1

STAGE 2

MODULE 3 – Sharing Corporate Resources

This module builds on, and increases, the knowledge gained in Stage 1.

It aims to provide the student with a thorough understanding of the comparability analysis once the transaction has been delineated and the significant comparability factors are taken into account. The comparability analysis is crucial to determine the correction (if any) required to calculate an arm’s length price.

Intra-group services will be studied to ascertain when these services are rendered, determine an arm’s length charge for these services and additional conditions relating to applying the OECD guidelines to intra-group services and low value-adding intra-group services.

The module further aims to ensure a student understands how certain of the more complex type of TP transactions are to be identified, treated, analysed, and priced according to the OECD guidelines.

The module aims to provide sufficient guidance to a student to identify Intangible transactions, their owners, how they are to be priced, how the transfer of intangibles is to be treated and priced, and allocations based upon the OECD guidelines and the arm’s length principle.

Learning outcomes:

On successfully completing this module, the student will be able to:

Knowledge (understanding)

Critically analyse the nine steps of a comparability analysis.
Evaluate the use of comparables in a comparability analysis.
Interpret OECD transfer pricing guidelines surrounding the charging for intra-group services.
Identify which intra-group services can be classified as low-value-adding intra-group services.
Identify intangible transactions for transfer pricing purposes as per the OECD Guidelines.

Skills (competencies)

Perform an appropriate comparability analysis once a transaction has been delineated and carry out the required adjustments.
Apply the comparability factors to each of the nine steps in a comparability analysis.
Determine Transfer Pricing on Intra-Group Services as per the OECD guidelines.
Verify the arm’s length charge for intra-group services and low value-adding intra-group services.
Analyse intangible transactions to apply the arm’s length principle to such transactions and implement any adjustments to these intangible transactions to adhere to the OECD guidelines for intangible transactions.

MODULE 4 – Specialised Areas

The module aims to provide:

The student with a detailed understanding of cost contribution arrangements and apply the arm’s length principle to such arrangements and how adjustments are to be made.
An understanding of the various types of financial transactions in a TP environment, including cash pooling. It includes guidance on how to price such transactions on an arm’s length charge.
Ensure a student understands how certain of the more complex type of TP transactions are to be identified, treated, analysed and priced in the OECD guidelines, specifically for business restructuring and permanent establishments.
Guide a student on what classifies as business restructuring and how the arm’s length principle is to be applied in such circumstances.
Guide the student on the arm’s length principle, Articles 5 and 7 of the OECD Model Tax Convention and the attribution of profits principles are explained in detail.

Learning outcomes:

On successful completion of this module, the student will be able to:

Knowledge (understanding)

Critically analyse the nine steps of a comparability analysis.
Evaluate the use of comparables in a comparability analysis.
Interpret OECD transfer pricing guidelines surrounding the charging for intra-group services.
Identify which intra-group services can be classified as low-value-addinglow value-adding intra-group services.
Identify and evaluate transfer pricing aspects of business restructurings.
Justify the applicability of the arm’s length principle for business restructuring transactions.
Interpret tax treaty definitions of what constitutes a permanent establishment as set out in the OECD Model Tax Convention.

Skills (competencies)

Evaluate an appropriate comparability analysis once a transaction has been delineated and carry out the required comparability adjustments.
Apply the comparability factors to each of the nine steps in a comparability analysis.
Determine Transfer Pricing on Intra-Group Services as per the OECD guidelines.
Verify the arm’s length charge for intra-group services and low value-adding intra-group services.
Execute the appropriate adjustments needed during a business restructuring to ensure the transaction is at an arm’s length price.
Calculate the arm’s length principle applicable to business restructuring transactions.
Apply the principles of the OECD Model Tax Convention on permanent establishments to determine whether a non-resident enterprise must pay income tax in another state.

ASSESSMENT SCHEME

Stages 1 & 2 (4 Modules)

The assessment scheme for each module shall consist of the following:

Coursework Assessment 1 (20 Marks)
Coursework Assessment 2 (20 marks)
Final Assignment (60 Marks)

Upon successful completion of Stage 2, you will automatically become eligible to progress to Stage 3—the Master’s (MSc) Dissertation.