ADIT Transfer Pricing Option
Online course starting on 7 May 2024
Get ready for the ADIT Transfer Pricing exam (Module 3.03) with our comprehensive 8-week online course starting on 7 May 2024!
In the ever-evolving landscape of taxation, staying ahead requires not just expertise, but mastery. The Advanced Diploma in International Taxation (ADIT) awarder by the Chartered Institute of Taxation, UK stands as a beacon of excellence in this journey, embodying a commitment to unparalleled knowledge and skill.
In the realm of taxation professionals' careers, ADIT has emerged as the hallmark of distinction, separating those who merely navigate from those who orchestrate. The Transfer Pricing exam is an essential component of ADIT.
Are you ready to embark on a transformative journey through the intricate realm of transfer pricing? Our comprehensive 8-week online course, "ADIT Transfer Pricing: Online Course," offers a wealth of enriching experiences and benefits that will set you on a path to mastery.
Course Highlights
🌍 Global Syllabus Alignment: Our agenda mirrors the ADIT's Module 3.03 - Transfer Pricing Option syllabus, ensuring you receive meticulously curated content that aligns with international standards and prepares you for success.
📚 In-Depth Learning Modules: Dive into a variety of engaging video lessons, each tailored to cover essential aspects of transfer pricing. From fundamental principles to advanced techniques, we've got you covered.
🔍 Case Studies and Real-World Scenarios: Gain practical insights through case studies that mirror real-world challenges faced by professionals. Apply your knowledge to intricate scenarios and refine your problem-solving skills.
🔒 Expert Instructor Guidance: Learn from Dr. Svetlin Krastanov, an ADIT Graduate and a distinguished tax adviser and lecturer with over 15 years of experience. His expertise bridges theory and practice, offering a unique perspective to guide you.
🏆 Mock Exams and Exam Preparation: Prepare effectively with three mock exams, accompanied by sample answers and insightful video commentary. Get tips and strategies for ADIT's Transfer Pricing Exam, setting you up for success.
📜 Certificate of Completion: Upon successfully completing the course, earn a well-deserved Certificate of Completion, showcasing your dedication and expertise in transfer pricing.
🗓️ Flexible Learning: Access course materials during the 8-week duration and continue learning for an additional 3 months after completion, allowing you to revisit content and solidify your understanding.
💡 Practical Application: Apply theoretical knowledge through assignments, quizzes, and case studies, enhancing your ability to handle real-world transfer pricing challenges.
Are you ready to elevate your career and seize the opportunities that await you in the dynamic world of international taxation? Enroll now and embark on a transformative learning experience that will shape your path to success.
🗓️ Key Dates:
- Course Starts: 7 May 2024
- Enrollment Deadline: 1 May 2024
🌐 Learn, Succeed, Excel! Your journey to ADIT success begins here. Join us and open doors to limitless opportunities.
Structure of the course
We understand that your time is valuable. That's why we've meticulously designed the ADIT Principles of International Taxation: Online Course to fit seamlessly into your busy life. With an 8-week duration, this course empowers you to become an international tax expert without overwhelming your schedule.
Each week's carefully curated content is structured to allow you to dive deep into the intricacies of international taxation while maintaining a manageable pace. We respect your commitments and obligations, which is why our course offers the flexibility you need to balance your learning with your professional and personal life.
By dedicating just a few hours each week, you'll witness your expertise in international taxation grow exponentially. Whether you're a working professional seeking to elevate your career or an aspiring tax specialist looking to build a strong foundation, our course duration ensures that your journey is both enriching and attainable.
Don't let time constraints hold you back from mastering the complexities of international taxation. Embrace this opportunity to transform your knowledge and open doors to a world of endless possibilities. Your journey to expertise awaits – and it's perfectly tailored to your schedule.
Agenda of the Course
Our agenda follows precisely the syllabus of the ADIT's Module 3.03 - Transfer Pricing Option. Below is the detailed agenda of the online course activities per weeks.
Week 1: Fundamental sources and the amr's length principle
📚 In this dynamic week, we'll be delving into the fundamental concepts and frameworks that form the foundation of transfer pricing. Get ready to embark on a journey that will equip you with the insights and knowledge needed to navigate the intricacies of this critical area of taxation.
Here's a sneak peek of what awaits you this week:
- Video lesson 1: Tax treaties, based on the OECD Model Convention and UN Model Convention, specifically Article 9 and “special relationship” in Articles 10-12
- Video lesson 2: OECD Transfer Pricing Guidelines
- Video lesson 3: OECD BEPS 2015 Final Reports (Actions 8-10): Aligning transfer pricing outcomes with value creation
- Video lesson 4: UN Practical Manual on Transfer Pricing for Developing Countries 2021
- Video lesson 5: Transfer pricing litigation cases (refer to the reading list)
- Video lesson 6: EUJTPF Codes of Conduct guidelines and reports
- Video lesson 7: Interpretation of the arm’s length principle and current dialogue
- Video lesson 8: Associated enterprises
- Video lesson 9: Global Formulary Apportionment
- Video lesson 10: Recognition of the actual transactions undertaken
- Video lesson 11: Losses and the effect of government policy
- Recommended readings: Online resources
- Case Studies 1, 2 and 3
- Graded Quiz 1
- Weekly Assignment 1
Week 2: Functional analysis
📚 As we continue our journey through the intricate world of transfer pricing, week 2 is dedicated to exploring the fundamental aspects of functional analysis and their critical role in selecting appropriate transfer pricing methods.
The activities in week 2 of the course include the following:
- Video lesson 12: The goal of functional analysis
- Video lesson 13: Analysis of functions, assets and risks (FAR)
- Video lesson 14: Relating functional analysis to selection of transfer pricing method
- Video lesson 15: Entity characterisation (e.g. characterisation as “entrepreneur”, stripped risk manufacturer, commissionaire, etc.)
- Video lesson 16: The practical approach to undertaking functional analysis
- Recommended readings: Online resources
- Case Studies 4, 5 and 6
- Graded Quiz 2
- Weekly Assignment 2
Week 3: Transfer pricing methods and comparability
📚 In this week's journey, we delve deeper into the intricacies of transfer pricing methods, comparability analysis, and the factors that shape the selection and application of these methods.
Here's a glimpse of the enlightening content you'll explore in Week 3:
- Video lesson 17: Description of methods
- Video lesson 18: Selection and application of the method(s) (including by reference to FAR analysis, entity characterisation and availability of comparables); the party to be tested
- Video lesson 19: The significance of comparability and factors determining comparability
- Video lesson 20: Performing a comparability analysis
- Video lesson 21: Dealing with the lack of comparable data
- Video lesson 22: Sources of information: internal/external comparables; “secret comparables”, foreign comparables
- Video lesson 23: Timing and compliance issues in comparability
- Recommended readings: Online resources
- Case Studies 7, 8 and 9
- Graded Quiz 3
- Weekly Assignment 3
Week 4: Specific transactions
📚 This week, we embark on a journey through various intricate aspects of transfer pricing, focusing on intra-group services, financial transactions, intangible property, business restructurings, and cost contribution arrangements (CCAs).
Here is an outline of the activities in Week 4:
- Video lesson 24: Intra-group services
- Video lesson 25: Intra-group financial transactions
- Video lesson 26: Intangible property
- Video lesson 27: Business restructurings
- Video lesson 28: Cost contribution arrangements (CCAs)
- Recommended readings: Online resources
- Case Studies 10, 11 and 12
- Graded Quiz 4
- Weekly Assignment 4
Week 5: Permanent establishments and compliance issues
📚 In week 5, we'll explore a critical intersection between transfer pricing and international taxation. This week's activities will deepen your understanding of how permanent establishments and business profits impact transfer pricing strategies, along with the essential documentation and compliance practices necessary for effective risk management.
Here's an overview of what you'll cover in Week 5:
- Video lesson 29: Article 5: Permanent establishments (OECD and UN Models)
- Video lesson 30: Article 7: Business profits (OECD and UN Models)
- Video lesson 31: Understanding the importance of PEs when dealing with transfer pricing
- Video lesson 32: Documentation (OECD BEPS 2015 Final Reports (Action 13); Country by country reporting, master and local file documentation formats)
- Video lesson 33: Examination practices, burden of proof and penalties
- Video lesson 34: Risk assessment and risk management
- Video lesson 35: Audits
- Recommended readings: Online resources
- Case Studies 13, 14 and 15
- Graded Quiz 5
- Weekly Assignment 5
Week 6: Avoiding Double Taxation and dispute resolution
📚 In this module, we'll delve into a range of advanced topics that are crucial for mastering the intricacies of transfer pricing. Week 6 is all about "Adjustments, Mutual Agreement Procedure, and Advanced Tools." These topics are pivotal for ensuring accurate and compliant transfer pricing practices across international borders.
Here's a glimpse of what you'll explore in Week 6:
- Video lesson 36: Adjustments
- Video lesson 37: Mutual agreement procedure, including OECD BEPS 2015 Final Reports (Action 14)
- Video lesson 38: Arbitration: Article 25(5)
- Video lesson 39: EU Arbitration Convention
- Video lesson 40: Advance pricing agreements (APAs)
- Recommended readings: Online resources
- Case Studies 16, 17 and 18
- Graded Quiz 6
- Weekly Assignment 6
Week 7: Other Issues
📚 In this module, we'll dive into contemporary and globally relevant aspects of transfer pricing that have a profound impact on international business and taxation. Week 7 is dedicated to "Emerging Trends and Recent Developments in Transfer Pricing."
The activities in week 7 of the course include:
- Video lesson 41: OECD/G20 Base Erosion and Profit Shifting (BEPS) Project
- Video lesson 40: Interaction between customs valuation and transfer pricing
- Video lesson 41: Safe harbours and tax incentives
- Video lesson 42: E-commerce and transfer pricing
- Video lesson 43: Worldwide recent developments in transfer pricing
- Recommended readings: Online resources
- Case Studies 19, 20, 21
- Graded Quiz 7
- Weekly Assignment 7
Week 8: Mock exams and closing of the course
📚 In week 8, we're focusing on fine-tuning your expertise and preparing you for the final stretch of your learning experience. Get ready for an intensive week of practice and guidance that will position you for success in the upcoming ADIT's Transfer Pricing Exam. Here's what's in store:
- 3 Mock exams
- Sample Answers to Mock Exams
- Videos with comments of the questions in the Mock Exams and sample answers
- Video lesson with useful tips for the ADIT's Transfer Pricing Exam
- Closing of the Course
Your Instructor
Meet Dr. Svetlin Krastanov - an accomplished tax adviser and esteemed lecturer boasting 15+ years of unparalleled experience in tax consulting. As the founder and owner of Tax Academy Ltd, an organization specializing in tax training and consulting, Dr. Krastanov's expertise is globally recognized.
With a rich professional journey spanning a decade at industry giants PricewaterhouseCoopers (PwC) and Ernst & Young (EY), Dr. Krastanov has provided strategic advice on intricate tax issues to an array of companies from diverse countries, including some of the world's largest multinational enterprises.
In addition to his consulting prowess, Dr. Krastanov has made significant contributions to the world of academia. He has delivered lectures on advanced tax concepts in multiple countries, offering a rare blend of practical insights and theoretical depth. His authoritative voice extends beyond the classroom, with his taxation publications featured in esteemed international journals.
Dr. Krastanov earned his PhD with a pioneering thesis on tax policy within the tourism industry in 2010. His quest for knowledge and excellence led him to achieve the Advanced Diploma in International Taxation (ADIT), awarded by the Chartered Institute of Taxation, UK. Additionally, he holds the distinction of being a Project Management Professional (PMP), certified by the Project Management Institute, US.
As an educator, consultant, and visionary in the realm of taxation, Dr. Krastanov brings an unparalleled wealth of knowledge to every learner seeking to master the intricacies of taxation.
Frequently Asked Questions
Dear Future Transfer Pricing Expert,
Congratulations on taking this significant stride toward becoming an esteemed transfer pricing specialist!
As we reach the conclusion of this page, I want to extend my heartfelt appreciation for embarking on the journey of exploration within our comprehensive "ADIT Transfer Pricing: Online Course." Your dedication to growth and excellence in the realm of transfer pricing is truly commendable.
Envision the satisfaction that comes with confidently navigating intricate cross-border transactions, providing expert counsel on transfer pricing complexities, and grasping the legal and ethical dimensions of international tax law. With the Advanced Diploma in International Taxation (ADIT) serving as a symbol of excellence, this course not only readies you for the transfer pricing exam but also elevates you as a knowledgeable and sought-after professional.
Guided by Dr. Svetlin Krastanov, an ADIT Graduate and an accomplished tax advisor with over 15 years of experience, you will delve into the intricate world of transfer pricing. Dr. Krastanov's wealth of knowledge and practical insights will empower you to master transfer pricing principles with confidence.
Your journey toward mastering the nuances of ADIT's Transfer Pricing exam commences here, and the opportunities that await are limitless. By enrolling in this course, you're not merely acquiring knowledge; you're investing in your career and positioning yourself for triumph.
With the course start date of May 7, 2024, swiftly approaching, I urge you to seize this moment to secure your place and elevate your expertise. Enrolling is straightforward—simply click the "Enroll in Course" button at the page's top or bottom, and follow the provided steps. Should you have inquiries or require assistance, please don't hesitate to contact us at [email protected].
Remember, this course is more than a vessel for learning; it's a catalyst for transformation. It's about equipping yourself with the wisdom and skills needed to confidently navigate the intricacies of transfer pricing.
Thank you once again for considering our course. We eagerly anticipate the privilege of guiding you through this enlightening journey and celebrating your achievements as a knowledgeable and adept transfer pricing professional.
Warm regards,
Dr. Svetlin Krastanov
Tax Academy
P.S. Your path to ADIT success commences with a single step - enroll now and embark on a transformative journey that will shape your career, unlocking an array of opportunities in the world of international taxation. Your commitment to growth is the key to unlocking a future of excellence.