U.S. Transfer Pricing and Global BEPS

⁨Course Description

Transfer pricing plays a critical role in determining how income is allocated among related entities operating across multiple tax jurisdictions. At the same time, global initiatives addressing base erosion and profit shifting (BEPS) continue to reshape international tax compliance and enforcement.

This course provides a foundational overview of U.S. transfer pricing principles and the global BEPS framework. Participants explore how transfer pricing rules apply to intercompany transactions, the arm’s-length standard, and the documentation requirements that support pricing positions. The course also introduces the objectives and structure of the OECD’s BEPS project and how these global initiatives influence U.S. and international tax compliance expectations.

Designed as an introductory-level program, this course helps practitioners understand key transfer pricing concepts, recognize BEPS-related risks, and identify situations that may require additional analysis or specialized expertise.

What You’ll Learn

After completing this course, you will be able to:

• Understand the purpose and scope of U.S. transfer pricing rules
• Explain the arm’s-length standard and its role in pricing intercompany transactions
• Identify common types of related-party transactions subject to transfer pricing rules
• Understand basic transfer pricing documentation requirements
• Recognize the objectives of the OECD’s BEPS initiative
• Identify how global BEPS developments affect multinational tax compliance

Who This Course Is For

This course is designed for:

• CPAs and tax professionals new to transfer pricing concepts
• Practitioners supporting multinational clients with intercompany transactions
• Tax staff seeking a foundational understanding of BEPS developments
• Professionals looking to build baseline knowledge of global transfer pricing issues

Key Topics Covered

Key topics addressed in this course include:

• Overview of U.S. transfer pricing rules
• The arm’s-length standard and its application
• Types of intercompany transactions subject to transfer pricing
• Introduction to transfer pricing documentation requirements
• Overview of the OECD BEPS project
• Key BEPS action areas affecting transfer pricing
• Global compliance considerations for multinational enterprises

Why This Course Matters

Transfer pricing and BEPS compliance are increasingly important areas of focus for tax authorities worldwide. Even at a foundational level, understanding these concepts helps tax professionals recognize potential risk areas, communicate more effectively with clients, and identify when specialized transfer pricing analysis may be required.

This course provides essential context for how U.S. transfer pricing rules interact with global BEPS initiatives. For additional guidance on transfer pricing and international tax policy, practitioners may refer to resources published by the Organisation for Economic Co-operation and Development (OECD) and the Internal Revenue Service (IRS).

Explore additional CPE courses in taxes available through NINJA CPE.

Frequently Asked Questions