Transfer Price Course & Transfer Price

Transfer Price Course & Transfer Price

10, 11, 26 and 27 February 2026 (08h30 to 12h30)

16 Points in EPC (CRC Continuing Professional Education/CFC)

Transfer Prices (Transfer Price) in Brazil: Law 14,596/23 / IN RFB 2161/23 (OECD Model

Online 'Transmission Live ' '5 Use of the ZOOM Web Conferencing App

The globalization of companies, the internationalization of production chains and new technologies have reinforced the importance of Transfer Pricing rules (Transfer Pricing) in the tax management of multinational companies.

In this context, the course will comprehensively address the theoretical and practical aspects related to this subject, offering participants the opportunity to study both Brazilian legislation and international experience.

The relevance of the study of the guidelines published by the Organization for Economic Cooperation and Development (OECD) is highlighted, considering the recent intention of the Brazilian Government to be part of this important international body. Thus, the preparation of the Transfer Pricing documentation according to the OECD guidelines will be addressed in detail during the course.

In order to provide an environment conducive to learning and debate, the course has been carefully designed to provide an appropriate forum for the study of practical cases and the orderly and in-depth discussion of the topics covered.

Over 16 hours of coursework, participants will have the opportunity to acquire relevant and practical knowledge about Transfer Pricing.In addition, the relaxed and interactive environment will enable the exchange of ideas and experiences among participants, further enriching learning.

In summary, the course will provide interested parties with a complete and updated training on Transfer Prices, contributing to the improvement of knowledge and the improvement of tax management practices in multinational companies.Do not miss this great opportunity to participate in an enriching, stimulating and conducive to knowledge sharing environment.

Target Public

Lawyers, accountants, economists, administrators and professionals who work in companies providing tax consulting services, foreign trade and multinational groups that want to have greater knowledge about Transfer Price (Transfer Price)

Methodology

Content presented dynamically, providing the debate and interactivity of the participants. The content presented will be available in electronic booklet (PDF).

Programmatic Content of Transfer Price Course & Transfer Price

Introduction

• Fundamental concepts of Transfer Pricing
• Objectives and importance of Brazilian legislation in this context
• Key challenges faced by multinational companies

OECD Guidelines “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration 2022” as subsidiary sources to Law 14.596/23.

The Universe of Operations

• The principle arm’s
• Controlled transactions
• Related parties
• Comparable transactions

The application of the Arm’s Length principle

• Mapping and understanding of operations
• Comparability factors
• Contractual terms
• Functional analysis
• Matrix of functions, risks and assets
• Characteristics of goods, rights and services
• Economic circumstances
• Business strategies

Introduction to comparability analysis

• Fundamental Concepts of Comparability Analysis
• Objectives and importance of Comparability Analysis in Transfer Prices
• Understanding the principles of comparability in transactions between related parties
• Key Factors of Comparability
• Identification of the characteristics of the relevant transactions
• Discussion of variables that affect comparability
• Sources of information and data for analysis
• Comparability adjustments

The calculation methods

• Of selecting the most appropriate method
• Comparable Independent Price Method & PIC
• Resale Price Method less Profit & PRL
• Cost plus Profit Method & MCL
• Net Margin Method of Transaction 5 MLT
• Profit Division Method ¡MDL
• Other methods
• The tested part

The range of comparable

Adjustments to the calculation basis

• Of compensatory adjustment
• Effects on other taxes

The documentation structure

• I. Country-by-Country Statement containing information relating to the overall allocation of revenues and assets and the income tax paid by the multinational group.
• II Global Archive, containing information on the structure and activities of the multinational group to which it belongs and the other entities that are part of the multinational group.
• III Local Archive, containing information relating to the transactions controlled and the related parties involved in the transactions controlled.

Case Study and Practice

• Simulated Case Analysis
• Application of practical exercise and correction

Closure and Review

• Recapitulation of Main Topics and Concepts

Reference legislation

• Law 14.596/23
• RFB Normative Instruction 2132/23
• RFB Normative Instruction 2161/23
• OECD Guidelines on Transfer Pricing for multinational companies and tax administrations

Instructor

Professional with more than twenty-five years of experience in tax consulting for multinational companies, working in different segments. Specialized in transfer pricing, tax planning, corporate restructuring and tax advice in the calculation of the tax burden. Founding Partner of Bluemind, leading projects of implementation of documentation routines, preparation of studies and calculations of Transfer Prices.

• Provision of tax consulting services for multinational companies in various segments.
• Advice on transfer pricing, tax planning and corporate restructuring.
• Tax burden calculation and optimization tax for international clients.
• Responsible for projects to implement Transfer Pricing documentation routines.
• Preparation of studies and calculations related to Transfer Prices.
• Specialization in the commodities, long-term projects, chemical, pharmaceutical and auto parts sectors.
• Supervision processes.

Academic Training

• Bachelor in Economics & Economics from Sao Paulo School of Economic Science
• MBA from Lake Forest University of Chicago

Publications & Lectures

• Author of the book “Transfer Prices in Brazil & Compliance & Economic Perspective”, 3rd edition, Sao Paulo, Customs.
• Publication of several articles on tax issues.
• Regular speaker at seminars in Brazil and Exterior.

Hourly Charge: 16 hours

Important Information

Date: 10, 11, 26 and 27 February 2026

Horário: 08h30 to 12h30

Investment: R$ 1490. Special condition for paid registrations until January 27, 2026: R$ 1,290. This value includes the course, material and certificate in electronic media.

Points in EPC (CRC Continuing Professional Education/CFC)16 POINTSAUD: 16, CMN: 16, SUSEP: 16, PROGP: 16, EXPERT: 16, PREVIC: 16, PRORT: 16, PREVICAUD: 16Company trained by CRC-SP: Barcino Training and Management Ltda. 00345 SP

Modality: Online Broadcast & The course will be broadcast live and students will be able to watch on a computer that has internet access. Students will be able to interact with the instructor, making comments and asking their questions during the course.

Did you finish the training and still have any questions?After the end of the training, students will have 30 days to solve their doubts with the teacher by email.

This training can also be conducted in company in face-to-face or online format.

More Information about the Transfer Price Course contact us at (11) 3230-2714 or access the link: http://bit.ly/BCN_TransferPrice_P