…Both For In-house and Independent Professionals
If you are looking for a quick and easy way to master transfer pricing, at your own pace, from the comfort of your home or office – even if you’re currently not a tax expert…
…Then this article is of interest to you.
Soon, you’ll be able to:
- Navigate transfer pricing challenges with confidence.
- Boost your skills with practical short-cuts found nowhere else.
- Become a sought-after authority in the work place.
My name is Wesley Thysse, Managing Partner of Transfer Pricing Asia, and I disclose exactly how to achieve this in a minute.
Do You Find Yourself Asking These Questions?
…How to choose the appropriate method?
…How to justify an arm’s length price?
…How to prepare the transfer pricing documentation?
…How to find good comparable data for an analysis?
…How to create a policy that satisfies the tax authorities?
You’re not alone. We have more than 10,000 visitors a month on this website looking for an answer to these (basic) questions. And no-one is answering them…. until now.
Luckily, there is now a simple and elegant solution to quickly master the fundamentals of transfer pricing…
What You’re About To Do
You’re about to discover a road-map through the maze of regulations. A selection of powerful insider transfer pricing tactics, presented to you in plain language, made alive with cases and examples. What’s included?
Fundamental Knowledge allowing you to:
- Obtain a deep understanding of transfer pricing.
- Explore transfer pricing methods in detail.
- Understand the laws and how to comply with them.
- Apply essential transfer pricing concepts with ease.
- Discover the key to a successful policy.
Practical information found nowhere else on how to:
- Succeed in finding comparable prices.
- Come to a decision on which transfer pricing method to use.
- Analyze prices – even without 100% comparability.
- Set the correct prices – by following a “Nine Step” formula.
- Unlock value for your company or clients.
- Craft compliant documentation – by using “Seven Building Blocks.”
- Draft a transfer pricing policy – and implement it into an organization.
- Avoid disputes with tax-authorities – by mitigating risk.
- Much, Much more.
But before I continue, I’ll introduce the people who went through the long and fascinating process of creating this material.
The Authors
Martijn de Lange LL.M. (hons)
Martijn is a transfer pricing expert with more than 12 years of professional experience working in London, the Netherlands and Hong Kong.
He started his career at the international tax department of Deloitte. He then obtained a position as a tax lawyer at Loyens & Loeff, a renowned tax law firm in the Netherlands. While there, Martijn successfully expanded the firm’s transfer pricing practice in the Netherlands and Asia. He then continued to work as an in-house Tax Director at a listed multinational, assuming responsibility for tax matters in the Asian region, and co-founded Transfer Pricing Asia. Besides his continued involvement in Transfer Pricing Asia, Martijn now works as an insurance broker specialised in tax insurance.
Martijn often lectures and publishes on transfer pricing. His key accomplishments include:
- Development of a two day course called “Dealing with Transfer Pricing in Asia” that presented to senior professionals and government regulators in both Manila and Hong Kong.
- Speaker at the IFA Asia-Pacific Regional Tax Conference (Singapore) and UIA Congress (Macau).
- Contributor to numerous transfer pricing articles in publications such as the Asia-Pacific Tax Bulletin, International Transfer Pricing Journal, Reuters and Bloomberg.
Martijn holds degrees in Tax Law (hons) and Corporate Law from Leiden University in the Netherlands.
Wesley Thysse Msc.
Wesley is a transfer pricing expert with more than a decade of professional working experience in Europe and Asia.
Wesley started his career in finance. He worked as a project controller at Multi Real Estate, a large developer of iconic shopping malls in Europe. He later settled in Dubai where, as a corporate service provider, he assisted entrepreneurs and high-net-worth individuals with international tax planning and legal structuring.
In 2014, he moved to Asia and started a small consultancy firm. He has since helped 100’s of SME’s and High Net Worth Individuals with international tax and transfer pricing issues. In 2016, he launched the website “Transfer Pricing Asia” to serve the region. It is now visited by more than 10,000 finance and tax professionals per month.
Wesley holds a Msc. degree in Management from the University of Greenwich, London.
What We’ve Created
Packing the largest amount of valuable transfer pricing information into an accessible format was no easy feat…
It started with a survey in 2017 of the visitors of this website. Many professionals like yourself expressed their frustration with the information available. This gave us a unique insight into what’s missing in terms of education.
We looked at the competition. Most text books are as dry and confusing as the OECD. There are a few overpriced introduction courses. A number of specialized seminars. But there was nothing addressing the practical aspects of transfer pricing in the real world.
To fix this, we first:
- Summarized all the relevant content from the OECD.
- Looked at text-books and their reviews to find out what’s readers want to see.
- Scrutinized the public material of Big 4 and other transfer pricing firms.
- Analyzed the recent media frenzy – and the actual laws it resulted into.
- Talked to clients and students.
We then combined all this into a list of topics. After pinpointing what we already had in terms of material, we proceeded to add a new piece of missing content every week. We focused on the techniques we use in our daily work to make this material as practical as possible.
We combined everything into one complete guide, and edited it three times from start to finish. Then, a professional native speaker edited it twice.
This process took us well over a year. Imagine the time it would cost to figure this out yourself!
The Result: Transfer Pricing: Rules & Practice
We created a clear and easy-to-read guidebook, containing all the information you need.
It focuses on practice, rather than theory. The lessons learned from it can be readily applied to real business situations and transactions. With it, dealing with transfer pricing issues will be a breeze!
This book is easily understood – even if English is not your native tongue, or if you don’t have a background in (tax) law. We spell each topic out in detail, with images, examples and cases.
We worked hard to create the best product available. Because we invested the time to base this book on real world demand and experience, we are confident that it will answer all your questions.
What Is Covered
A number of chapters divide this exclusive book, each discussing a different topic. Each introduces essential tools and resources, and step-by-step systems you can use when meeting your regulatory obligations.
- Chapter 1 tells you exactly what transfer pricing is. It also defines key concepts in detail, such as: Associated Enterprises, Controlled Transactions and the Arm’s Length Principle.
- Chapter 2 outlines why transfer pricing is such a hot topic; diving into “profit shifting” and “erosion of the tax-base.” It shines a light on the attention it gets from politicians, lobby groups and the media, and how this contributed to the world-wide implementation of (broadly similar) legislation.
- Chapter 3 unveils a “Nine-Step Process” for pricing transactions. It reveals where you can find internal and external prices for your benchmark – and how to correctly analyze this data.
- Chapter 4 examines the five transfer pricing methods and details when each should be used. Next, we reveal a simple (but essential) tool to fortify your transfer pricing against challenges from tax authorities. This prevents potential audits and disputes.
- Chapter 5 raises the bar with “Seven Building Blocks” to construct documentation from scratch. By doing this yourself, you can save time and legal fees.
- Chapter 6 spells out how to craft a transfer pricing policy and integrate this in the day-to-day practice of a MN. It discusses overcoming the practical hurdles you’ll likely encounter. Lastly, it includes drafting tips for transfer pricing agreements, another major component that is often overlooked.
- Chapter 7 isolates common focus points of tax authorities, and presents five measures you can take to avoid audits and disputes.
- Annex I includes additional guidance on the creation of the Master File, the Local File and the Country-by-Country Report.
As you see, each essential aspect of transfer pricing is included. But this is just a summary. To see exactly what is covered, make sure to check out the Table of Contents…
Testimonials
Zofia Mika
“Practical guidance accessible for everyone who’s interested in transfer pricing. Very well written, clear, full of examples and case studies .. Great piece of work! Huge compliments to the authors!”
Ruud Waals
“Very well written, very clear, and I like the approach you have of transfer pricing.”
Tim Mulder Testimonial
“This book is great. The authors explain transfer pricing in simple terms and have included a large number of useful examples. In my view this is a must read for any professional who deals with transfer pricing.”
Alexandros Testimonial
“Had a read through the TP manual last weekend. Awesome. Its very explanatory. I love it! Simple language simple examples. Makes sense. Man felt like my ACA student days. It felt like reading my ICEAW manual. You can take that as a compliment. The manuals were very good! Its not an easy task to explain something out of a book.”
Joy Testimonial
“Thank you for these materials! I am reading through them currently. The book is well organized and easy to understand with good examples which makes it enjoyable.”
Tim Testimonial
“This book is a product that everyone working in an in-house tax or transfer pricing role should have on their desk. What sets it apart from other TP related books is the practical approach. Unlike many other publications, it gives good quality examples and solutions for real life TP cases and it is not limited to addressing OECD TP guidance only.”
But that's not all...
Bonus 1 – Transfer Pricing Training Module:
To test if you're ready for battle, we created a Transfer Pricing Training Module. This dynamic and challenging training sharpens your instincts, and prepares you for a life in the trenches of the modern transfer pricing practice.
It starts with twenty multiple choice questions. Most can easily be answered with the help of the book. Others require you to navigate your way through external sources – Introducing the exact-same resources professionals use on a daily basis.
Next, you’ll encounter six unique cases based on our experience in the field. These are more challenging. You’ll need to use everything in your new toolkit when exploring advanced topics such as:
- Assessing Transfer pricing risks.
- Calculating the tax effects of a business restructuring.
- Identifying "hidden" transactions.
- Consolidate income tax rates.
- Substantiating the selection of transfer pricing methods.
- Determining comparability.
- Isolating controlled transactions.
- Creating a transfer pricing policy.
- Implementing dispute avoiding measures.
- Multi-jurisdiction tax planning.
- Analyzing revenue thresholds for documentation requirements.
- And more...
This is currently not on the market anywhere else. And what's more, you can consume this training wherever you feel comfortable, and come back to refresh your knowledge as often as you like.
Currently, seminars are the most common way to train. They often cover only primary, or very specific topics, go too fast or too slow, and seldom teach you what you need to know. Moreover, they cost up to USD 1,000 USD to attend – excluding the costs for travel, hotels and hours lost.
And there's more...
Bonus 2 – Transfer Pricing Case Law:
There is an increasing number of transfer pricing disputes, which are often fought out in court. The resulting case law provides valuable insights on strategies and positions of taxpayers and tax authorities alike. Case law is where the rubber meets the road.
Accordingly, this second bonus cuts through seven interesting court cases like a laser. We analyze what the MNE in question did and how this led to a dispute. We look at the rulings, and provide analysis as to why the cases ended as they did.
Case law deepens your understanding of transfer pricing, and helps you become more knowledgeable and confident. What's interesting, is that you can see the lessons from our book directly back in court-rulings.
Frequently Asked Questions
Yes, this book is written based on the OECD Guidelines, which is what is being implemented worldwide. It is true there are small variations in the interpretations by domestic legislatiors. We account for those. The general principles, however, are the same everywhere.
More over, we have practical experience with transfer pricing in Europe, North- and South America and Asia (of course).
Yes, we wrote this material as simply as possible. One of the reason our articles are successful on the Internet is exactly because they are easy to read.
This means that even if your English isn’t 100% perfect, this book is by far the best option out there.
This book is written for a wide audience. This means everybody can grab it and quickly gain a deep understanding on transfer pricing. However, it is most useful for:
- In-house tax/finance professionals
- Accountants / Tax advisors
- Students
- Tax directors/managers
- Independent advisors
- Tax authorities
- Everybody else in need of a deeper understanding of transfer pricing
In short, because this was written for people like you. We addressed what the biggest challenges are, what information is missing, and what the biggest struggles are for understanding transfer pricing.
Next, we have a combined 19 years of professional working experience to quickly cut to the chase and tell you what is important. What methods are used and when. What tax authorities look at (and how to deal with them). How to implement a policy into an organization. Where to find good data to compare. Where to set prices. And much more!
Unfortunately, existing papers and books written on transfer pricing don’t cover the topic well. In addition, the guidelines from the OECD are too vague. But worse, nothing discusses the reality businesses face now transfer pricing regulation has been rolled out worldwide.
We fixed this. This book wasn’t created overnight. If you include the articles we used, this book was produced over a period of almost three years. During this time, we got a good idea of what is needed.
We are excited about this book! It can help you handle this topic better. Transfer pricing isn’t rocket-science. But it isn’t a picnic either. It surely is poorly explained; and not widely understood.
The most important players, such as the Big 4, do not want to reveal their tactics. This would mean more competition, and more informed clients. They have ZERO interest in this.
Luckily, you found this book. By reading it – and studying the examples, cases and questions – you’ll join a small group of insiders who understand transfer pricing.
The agreement is designed to be valid in countries all around the world. It contains all the key elements for the contract to be valid (e.g., consideration, performance, terms, governing laws and jurisdiction, etc). As it is impossible for us to publish a template that covers all country specific particularities, we advise to check with your internal or external counsel if amendments are required. If needed we can review the agreement or create one for you for a fee..
Transfer pricing documentation substantiates the right transfer pricing arrangements.However, it is not legally binding. Intercompany agreements help you to implement and formalize the transfer pricing arrangement in a legally binding contract between associated enterprises. Other than certainty within your business, this also creates evidence towards the tax authorities that the transfer pricing arrangements have been implemented and formalized correctly.
There is not one set of requirements that applies to all transfer pricing agreements in all jurisdictions. Even the OECD does not provide specific guidance on what information must be included in transfer pricing agreements. This makes sense; they are providing guidance for countries around the world, with different legal systems and focus areas.
Moreover, there is tremendous freedom for private parties to design agreements (freedom of contract). Our agreements contain all the essential aspects such as parties, scope, controlled transaction and arm’s length remuneration and give clear instructions. Other than that, the agreements can be adjusted to suit your needs.
There are many important considerations, but we highlight three of them:
- Ensure that the agreement is in line with reality; if you invoice a cost+ mark-up of 4% while an agreement states 6%, this can raise eyebrows. This might seem obvious, but over time such discrepancies often happen within enterprises.
- Similar to the above; ensure that the agreement is consistent with TP documentation. If the conclusion of TP documentation is that a royalty fee should be 5% of the annual net revenues while the agreement provides for a royalty fee of 15%, this will probably not be accepted by the tax authorities.
- Ensure that the agreement incorporate market standards: The starting position with transfer pricing is that associated enterprises should transact with each other as if they were third parties. Hence, you expect market standard terms and conditions in the agreement. For example, if third party lenders normally require a borrower to provide securities for the repayment of the loan, it wouldn’t make sense to leave that out in an agreement between associated enterprises.
Absolutely! The absence of intercompany agreements is considered a red flag and a sign that the transfer pricing is not in order. If you can show a clear, up-to-date, and compliant agreement in line with reality, this helps tremendously in defending your transfer pricing positions.
The Price:
I guess by now you are convinced this is great. I bet you have a few questions. How much does it cost? Am I guaranteed to get the result I need? How do I get my hands on it?
Before we dive into that, let's recap what you’re getting:
The Book – Transfer Pricing: Rules & Practice: The most complete guidebook on practical transfer pricing currently on the market. It's hard to place a value on this book, because it provides many short-cuts not found anywhere else:
- A basic strategy call with a transfer pricing expert to determine the best transfer pricing method would cost around USD 500-1,000. After all, they must completely analyze the business and the controlled transaction(s). Wouldn’t it be nice if you could handle this? Chapter 4 spells it all out.
- Firms often charge USD 5,000 or more for a Transfer Pricing Analysis of a controlled transaction. Chapter 3 gives you a “Nine Step Process” you can use to substantiate arm's length prices.
- Even one "Dispute Avoiding" suggestion mentioned in Chapter 7 could be the difference between a standard (busy) year-end closure, and finding yourself at the center of an audit.
- What other way is there to instantly improve your value in the work-place, by bringing a set of rare and in-demand skills to the table? Become the go-to-expert as far as transfer pricing is concerned.
Bonus 1 – Transfer Pricing Training: A fun and challenging set of questions, ranging from basic to advanced topics.
- Frankly, there is no other material that can be studied at your own pace, is accessible online, and doesn’t focus on a specific country. I found a Fundamentals of Transfer Pricing course from a famous tax institute, covering only the topics in the first two chapters of our guidebook.
The price they charge is: 674 USD (Excl VAT).
Bonus 2 – Case Law Review: A unique look under the veil of transfer pricing disputes by analyzing real-world court rulings.
- Imagine your first steps into case-law would consist of having to go through a 286-page court ruling. Luckily, we have done this for you. It comes as a free bonus, to the already extensive content in the book and training module.
You might expect to find all this value behind a massive price-wall. But I want to make this product inclusive, and available to a wide-range of visitors. Therefore, this complete package is available for only 197 USD.
This is less than you’d have to pay for one hour of my time, much less than any one-day seminar out there, and far less than any course available.
What You'll Get:
After you made the choice to purchase, you’ll automatically receive three PDF files:
- The Guidebook: Transfer Pricing: Rules & Practice;
- The Transfer Pricing Training Module; and the
- Transfer Pricing Case-Law Review.
You can save them anywhere, and open them with Adobe, or any other program capable of reading pdf’s (like your browser). The are no restrictions or passwords. Once it’s yours, it’s yours.
You‘ll have unlimited access to the material. You can print it, or upload it on your phone or tabled. Read it any time you want. Have it on the ready when you need to solve a transfer pricing puzzle.
If you don’t like the product for any reason, Iwe'll give you a full refund and you can keep the book and the bonuses. For accounting reasons, do let us know within 30 days if you're not happy with your purchase.
The laws have been implemented. Aren’t you prepared yet? Then you need this product and no-one else is offering it. It’s a great product: and frankly all you need to start tackling transfer pricing issues today.
What To Do Next:
By now you understand this is the most convenient, affordable and low-risk way to start your transfer pricing journey.
The next step is to click on the "Buy Now" button below. Checkout is done by Paypal. Payment is done to our company account: Thysse de Lange Limited.
It all goes automatically, and you'll be redirected to an instant download page. In addition, You'll receive a notification by email with a link to the correct material.
With this material, you get yourself a road-map. It takes you on a journey of discovery: Explore new concepts, learn insider tactics, and execute powerful tools. This is an investment in your career.
You should jump on this right now. You have no idea what is going to happen next or if this offer is going to be around at this price. No-one is teaching this because it isn't in their interest to do so. Big firms are making transfer pricing appear more complex than it is. They want to keep the competition out. If you're smart, you click on this button and become instantly one of the few who can safely lead others through the transfer pricing landscape for years to come.
So congratulations on taking this important step, and...
...Welcome to the wonderful world of transfer pricing!
See you on the inside.
Click here to buy:
Kind regards,
Wesley Thysse
Managing Partner
