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Advanced Principles of Taxation & Transfer Pricing: Concepts, Application & Integrated Practice
Booking options
€270 - €550
Dates
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Highlights
Live Online
14 CPD Units | 14 Hours
HRDA Subsidised
The EIMF Live Online Learning Experience
Participants will receive access to the recorded sessions of the course.
EIMF subject-matter experts deliver engaging and interactive courses across a broad spectrum of areas, that can be enjoyed in the comfort of your own chosen environment. Read more
Course Overview
International taxation and transfer pricing have become increasingly interconnected as organisations expand across borders, adopt complex operating models, and align with global regulatory expectations.
Understanding how tax systems operate, how double tax treaties apply, and how the arm's-length principle shapes intra-group pricing is essential for managing financial risk, ensuring compliance, and supporting strategic decision-making.
This comprehensive programme provides an in-depth exploration of advanced tax principles and OECD-based transfer pricing frameworks, taught first as standalone subjects and then merged to demonstrate how they interact in real-world business environments.
Participants will learn to analyse cross-border transactions, identify risks, interpret treaties, determine permanent establishment exposure, perform functional and risk analyses, apply transfer pricing methods, and prepare documentation.
Through practical examples, case studies, and integrated exercises, the programme will equip participants with the technical and practical skills required to navigate modern tax and TP requirements with confidence.
Training Objectives
By the end of the programme, participants will be able to:
Explain core concepts of domestic and international taxation
Analyse residence, source rules, and permanent establishment exposure
Interpret double tax treaties using the OECD Model Convention
Identify cases of double taxation and methods of elimination
Understand anti-avoidance regimes (GAAR, SAAR, CFC, ATAD, BEPS)
Explain the arm's-length principle and OECD TP Guidelines
Conduct functional, asset, and risk (FAR) analysis
Select and apply appropriate transfer pricing methods
Evaluate tax and TP implications of cross-border intra-group transactions
Integrate tax and TP concepts to assess real business scenarios and risks
Strengthen internal compliance, documentation, and governance frameworks
Training Outline
Part A: Advanced Principles of Taxation Introduction to International Taxation
Purpose and evolution of international tax rules
Interaction of domestic and foreign tax systems
Key definitions and foundational concepts
Residence & Source Principles
Corporate and individual residence rules
Source-based jurisdiction
Practical examples across industries
Permanent Establishment (PE)
Definition under OECD Model
Fixed place PE, agency PE, digital PE
Case studies and practical implications
Double Tax Treaties
Purpose and structure of treaties
OECD vs UN Models
Treaty interpretation principles
Application to different income types
Double Taxation & Elimination Methods
Identifying situations of double taxation
Exemption and credit methods
Practical examples
Anti-Avoidance Rules
Distinction between tax evasion and avoidance
GAAR, SAAR, TAAR
CFC rules, hybrid mismatches, interest limitations
ATAD and BEPS developments
Tax Case Studies
Cross-border business scenarios
PE identification
Treaty application
Part B:Transfer Pricing Introduction to Transfer Pricing
Purpose of TP and global regulatory framework
OECD Transfer Pricing Guidelines
The arm's-length principle
Functional, Asset & Risk (FAR) Analysis
Identifying functions performed
Risk ownership and control
Intangibles and value creation
Examples from multiple industries
Transfer Pricing Methods
CUP, RPM, Cost Plus, TNMM, Profit Split
Method selection criteria
Practical application exercises
Intra-Group Transactions
Intercompany services and cost allocation
Loans, guarantees, and financial transactions
Licensing and IP-related arrangements
Goods and supply chain structures
Transfer Pricing Documentation
Master File
Local File
Country-by-Country Reporting (CbCR)
Benchmarking studies
Internal controls
TP Case Studies
Selecting TP methods
Assessing comparability
Real-world examples
PART C: How Tax & Transfer Pricing Merge Interaction Between Tax & TP
Why TP cannot be assessed without tax principles
Alignment of PE analysis, treaty interpretation, and pricing outcomes
Combined effect of BEPS measures
Holistic Evaluation of Cross-Border Transactions
A unified approach to tax + TP analysis
PE creation through intra-group arrangements
Misalignment risks and regulatory scrutiny
Developing Integrated Policies & Controls
Governance expectations
Documentation strategies
Internal review frameworks
Full Integrated Case Study
Analyse residence, source, and PE implications
Apply treaty provisions
Select TP methods
Prepare key documentation elements
Identify combined tax and TP risks
Discussion & Q&A
Who Should Attend
This programme is suitable for professionals from all industries, including:
CFOs, Finance Directors & Controllers
Tax Managers & Consultants
Accountants & Finance Officers
Internal Auditors and Risk Officers
Compliance Professionals
Legal & Corporate Services Professionals
CEOs, Business Owners & Senior Executives
Anyone involved in cross-border transactions or intra-group pricing
Training Style
The programme uses a blended approach of structured lectures, practical examples, interactive discussions, and real-life case studies.
Participants progressively build technical understanding and apply concepts through scenario analysis and integrated exercises, ensuring both theoretical knowledge and practical, workplace-ready skills.
CPD Recognition
This programme may be approved for up to 14 CPD units in Accounting and Auditing. Eligibility criteria and CPD Units are verified directly by your association, regulator or other bodies which you hold membership.
In-house Training
For groups within the same organisation, this course may be customised to meet any specific needs and delivered in-house.
Facilitators
Andriana Zenios
Andriana Zenios, FCCA, AIA, AAT, is an accomplished international finance executive and strategic advisor with over 25 years of leadership experience across Europe, the UAE, the Middle East, and Africa. Her career spans senior roles including Group Chief Financial Officer, Executive Director, Board Member, and Strategic Advisor, guiding organisations through growth, restructuring, governance transformation, and complex multi-entity expansion. Andriana brings a distinctive blend of financial clarity, strategic leadership, and governance discipline. She has built and led high-performing teams, designed robust executive and control frameworks, and supported organisations during critical transition phases, consistently focusing on measurable impact, risk management, and long-term value creation. Her experience extends to Family Office setup and management, where she has overseen wealth structuring, investment strategy execution, reporting, and governance. As Founder & CEO of EliteExec Strategic Partners, Andriana provides fractional C-Suite services, governance advisory, and executive-level financial leadership to organisations seeking experienced, hands-on support. She works closely with boards, founders, and senior management teams, helping them strengthen decision-making, navigate complexity, and translate strategic vision into structured, sustainable results. Alongside her executive career, Andriana has been a lecturer for over 20 years, delivering professional education to executives and finance professionals. She is widely recognised for her clear, practical, and engaging teaching style, enabling participants to confidently apply complex concepts in real-world business environments.