The Power to Govern, the Duty to Account
CENTS Governance Academy

Executive & Specialist Programmes

Transfer Pricing and Profit Shifting

Profit leaves a country through prices set between related parties, and each transaction looks ordinary on its face. We teach the analysis that proves it and the audit that recovers it, including the comparables problem no textbook solves.

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Programme overview

Profit leaves a country through prices set between related parties, and each transaction looks ordinary on its face. We teach the analysis that proves it and the audit that recovers it, including the comparables problem no textbook solves.

This specialised subject can be taken as a one-day working lab, three-day workshop, two-week specialised training, or curated institutional programme within published open windows.

Who should attend

Transfer pricing and audit units, international tax officers, large taxpayer offices, revenue boards.

Programme modules

Module spine

  1. 01

    Functional analysis where the contracts do not match the conduct

  2. 02

    Pricing intangibles, brand and hard-to-value transfers

  3. 03

    Intra-group finance, parent guarantees and thin capitalisation

  4. 04

    Building an audit without comparables: proxies, databases, safe harbours and simplified approaches

  5. 05

    Defending the adjustment: documentation, advance pricing agreements, mutual agreement procedure and litigation risk

  6. 06

    Capstone: a risk-based case selection and enforcement programme for a large taxpayer office

Learn from practitioners

Specialist lead