Global BEPS and Introduction to U.S. Transfer Pricing
Global BEPS, U.S. BEAT, and transfer pricing rules create complex compliance risks for multinational businesses and their tax advisers.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
2
Author(s)
AICPA staff
Availability
1 year
Product Number
USITGBTP26SSO
Global tax rules in context
Global tax rules continue to evolve as governments respond to base erosion, profit shifting, digitalization, and cross-border related-party transactions. You will discover the Organisation for Economic Co-operation and Development (OECD) and G20 base erosion and profit shifting (BEPS) framework, including:
- Pillar 1 concepts
- Pillar 2 and Global Anti-Base Erosion (GloBE) rules
- BEPS 15-point action plan
- Country-by-country reporting (CbCR)
- Base erosion anti-abuse tax (BEAT)
Transfer pricing compliance essentials
Learners will examine the three-tier transfer pricing documentation approach, country-by-country reporting, and Section 482 principles, including:
- The arm’s-length standard
- The best method rule
- Comparability analysis
Learners will also cover common transfer pricing methods for tangible property, intangible property, and services transactions.
Practical risk and penalty considerations
The course highlights how transfer pricing adjustments can affect U.S. taxable income, BEAT, net controlled foreign corporation tested income (NCTI), foreign-derived deduction-eligible income (FDDEI), Subpart F, foreign tax credits, import/customs issues, and conforming adjustments.
Note: This program includes content from the U.S. International Tax Certificate.
Who Will Benefit
- Tax professionals advising multinational businesses
- CPAs working with international tax or transfer pricing matters
- Corporate tax and finance professionals responsible for related-party transactions
- Professionals seeking an introduction to BEPS, BEAT, and U.S. transfer pricing compliance
Key Topics
- OECD BEPS framework
- Pillar 2 and GloBE rules
- Country-by-country reporting
- U.S. BEAT rules
- Section 482 transfer pricing
- Arm’s-length standard
- Transfer pricing methods
- Section 6662 penalties
Learning Outcomes
- Determine the primary drivers of BEPS and apply them to real-world multinational structures.
- Identify transfer pricing risk factors in cross-border related-party transactions.
- Recognize penalties for failure to meet transfer pricing compliance requirements.
Group ordering for your team
2 to 5 registrants
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