Principles of International Transfer Pricing

50+ hours of video, 24 hours of classes & source documentation for ADIT CIOT Mod 3.03 exam

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The aim of this course is two fold:

  1. It provides students with an overview of international transfer pricing, over what would be a full 5 day course if taught in person;
  2. It helps prepare students doing the UK Chartered Institute of Taxation (CIOT) doing the Advanced Diploma in International Taxation (ADIT) for Module 3.03 - Transfer pricing, by discussing all topics required in their 2024 syllabus.


Students are taken through:

  • basic concepts in transfer pricing such as the arm's length principle, functional analysis, comparability and transfer pricing methods;
  • the OECD Transfer Pricing Guidelines and the UN Practical Manual on Transfer Pricing;
  • specific transactions, permanent establishments, compliance issues and dispute resolution; and
  • recent developments in case law, treaties and at intergovernmental fora such as the UN, the OECD and the EU.

  1. You get 50+ hours of video lectures available as soon as you sign up. Each lecture typically lasts 12 - 20 minutes.
  2. We have 9 interactive online classes Sa. 11 AM - 1 PM Amsterdam time between 17 August and 19 October 2024. Classes will be recorded for review and for those who cannot attend.
  3. You get 3 interactive online exam preparation classes from 30 November in which we discuss old papers and best exam strategies.
  4. You get continuous support. We respond within 24 hours to questions and comments you may have and are always ready to explain any material you may find difficult to understand.
  5. You get quizzes after each pre-recorded lecture section to test your knowledge, together with 2 interim online multiple choice test, a final multiple choice test, and an essay type exam to monitor your progress and give you feedback on your writing style for the ADIT exams.
  6. You have access to all videos and classes for 2 years since your signup.
  7. The course is updated and new lectures are added on a continuous basis to ensure that students have up to date information when going for the exams.

Note for our students from outside the EU: if you experience any difficulties in getting your credit card payment accepted, please let us know at [email protected] and we will send you a payment link via Stripe, as soon as possible, usually within 2 hours.


Your Instructor


Johann H. Müller
Johann H. Müller

My passions are tax and teaching. I love reading and understanding treaties, laws and directives; seeing how they are shaped in case law and then explaining all that in clear, simple terms with references to real life practical examples. I enjoy interacting with people, raising questions and getting them to connect the dots so that ultimately they feel comfortable with the material and their skills.

I teach transfer pricing, international corporate taxation, and Pillar 2 in a variety of formats: online automated, online face to face, and in person. My typical audiences are: governments, universities, tax professionals with continued education requirements, professional service providers and post graduate students following the Chartered Institute of Taxation’s exams for an Advanced Diploma in International Taxation (#CIOT and #ADIT).

In my teaching I bring to the table my 25+ years experience in international tax and transfer pricing from working in Amsterdam, London, New York and Copenhagen; working for large law firms, accounting firms, the Danish government and various multinationals in various industries. I also published books and numerous articles on taxation, and am currently the editor of PE Plus, an international database on the taxation of permanent establishments.

Please have look at:
Bettertax.info - our business website;
Our Youtube channel where we discuss various tax topics; and
LinkedIn - for my personal profile. Send me an invite so we can stay in touch :-).

You can reach me at: [email protected] or +45-6120 2911.


Course Curriculum


  00. General information
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  I. The fundamental sources of transfer pricing
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  II. The Arm's length principle
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  III. Functional analysis
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  IV. Transfer pricing methods
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  V. Comparability
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  VI. Specific transactions
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  VII. Permanent establishments (PEs)
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  VIII. Compliance issues
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  IX. Tax disputes and avoiding double taxation
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  X. Other issues
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  XI. Old exams
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  XII. Case law
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  XIV OECD TPG podcasts
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Frequently Asked Questions


When does the course start and finish?
You are the master of your time! It is a completely self-paced online course - you decide when you start and when you finish.
How long do I have access to the course?
You have access to the course material for 2 years. Does that not beat attending a live course where its done when its done?
What if I am unhappy with the course?
We would never want you to be unhappy! If you are unsatisfied with your purchase, contact us in the first 30 days and we will give you a full refund.

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