Paper 3 – TP


  • Course location: Kazakhstan, Russia, Slovakia, Czech Republic, Hungary, Brazil, South Africa
  • Lecturer: JUDr. Tomas Balco, LL.M., FCCA
  • Price: depends on location of the course
  • Duration:  6 days (2 days in October, September and November 2015)
  • Materials: hard copy of study materials and access to online library


Preparatory course for Paper 3 – Principles and practice of Transfer Pricing is carried out in 2 models:

  • Introductory course, which consits of 4 days of trainings
  • Revision course, which consits of 2 days of trainings

Introductory course is intended to establish sound theoretical foundation for all the ADIT syllabus areas which will be also combined with practical application of the theory on practical cases.  This session is also suitable for tax practitioners, who do not wish to have ADIT qualification but are interested to advance their understanding of tranfer pricing.

Revision course is designed to assist students to further develop ADIT exam technique and is focused on reviewing the critical areas of syllabus on real exam questions to enhance their chances of passing the exam.

Content of Introductory course:

    Day 1: Introduction to Transfer Pricing

  • 1.1. The Arm’s Length principle  and attribution of profits between associated enterprises
  • 1.2. Permanent establishments and attribution of profits
  • 1.3. Fundamental sources of Transfer Pricing

    Day 2: Determination of Transfer price in     practice

  • 2.1. Functional analysis  in practice
  • 2.2.Description of Transfer Pricing methods
  • 2.3.  Selection and application of transfer pricing methods
  • 2.4. Role of comparability analyses and its practical application

    Day 3: Specific transactions

  • 3.1. Intra-group services
  • 3.2. Intra-group financial services
  • 3.3. Intangible property
  • 3.4. Business restructuring
  • 3.5. Cost-contribution agreements

    Day 4: Compliance issues and miscellaneous   topics

  • 4.1. Documentation and risks management
  • 4.2. Methods for avoiding double taxation and resolving disputes
  • 4.3. Overview of BEPS initiative and recent developments in respect of transfer pricing
  • 4.4.  Miscellaneous topics

In-house training are available. Please contact Our Team for further details at 

Contact Our Team at to register for preparatory ADIT courses.

Consult CIOT website for deadlines to register for ADIT exams!

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