Transfer pricing - Foundations

Technical requirements:

• A personal computer (recommended), tablet or smartphone
• An up-to-date internet browser (Google Chrome recommended)
• Cookies should be enabled
• JavaScript should be enabled
• A stable internet connection

Should the internet connection be lost during an e-learning session, the browser will need to be restarted when internet is back to resume the e-learning at the last step recorded by the learning management system before the connection went out.

Transfer pricing is a critical area for multinational enterprises, as it directly influences how profits are allocated across jurisdictions and how tax obligations are determined. As tax authorities continue to increase their scrutiny, understanding transfer pricing has become essential for many business functions.

This AI-supported learning experience is designed for professionals who are new to the topic and want to build a strong foundation in understanding how transfer pricing works in practice. Whether you are part of a finance team, a tax function, or simply looking to broaden your knowledge, this course will guide you through the essential principles, terminology, and regulatory context governing intercompany transactions.

Through practical explanations and real-world context, the training explores what transfer pricing is, why it matters, and how it is applied in practice. Particular attention is given to the arm’s length principle, the assessment of intercompany pricing, and the role of transfer pricing policies and documentation in ensuring compliance.

This e-learning embeds content entirely created by PwC experts and delivered through AI-powered visuals.

By the end of this e-learning, participants will be able to:

• understand the purpose of transfer pricing and its role within multinational groups;
• identify the key aspects, principles, and terminology of transfer pricing;
• recognise why transfer pricing is increasingly in focus for tax authorities;
• understand the impact of transfer pricing on tax, finance, and business operations;
• follow the main steps involved in assessing transfer pricing arrangements;
• gain awareness of transfer pricing policy setting and documentation requirements;
• develop a high-level understanding of the Luxembourg transfer pricing framework.

• Purpose and objectives of transfer pricing
• Key aspects and basic principles of transfer pricing
• Impact of transfer pricing on multinational enterprises
• Steps in assessing transfer pricing, including the arm’s length principle
• Transfer pricing policy setting and documentation
• Overview of transfer pricing in Luxembourg

We deploy our e-learning solution as from 10 licences.

The price per licence varies on quantity purchased:

• From 10 to 50 licences: EUR 75 each;
• From 51 to 150 licences: EUR 70 each;
• From 151 to 300 licences: EUR 60 each;
• From 301 licences: EUR 50 each.

This digital learning has been designed with the support and collaboration of Marc Rasch, Partner in charge of transfer pricing, Christophe Hillion, Tax Partner, and Konstantinos Myaris, Director at PwC Luxembourg.

Marc is specialised in transfer pricing, with a focus on financial transactions, banking, operational industry, country-by-country reporting and dispute resolution. He has over 25 years of experience in transfer pricing and international taxation. Prior to joining PwC in Luxembourg, he worked in Paris and in the Netherlands. Marc regularly publishes transfer pricing articles and participates as a speaker at seminars. Marc has been nominated as a leading TP specialist in Luxembourg by Euromoney/International tax review.

Christophe is a Transfer Pricing partner specialist focusing on financial transactions, the Alternatives funds industry and the Insurance industry. He has over 20 years of experience in transfer pricing and international taxation. Prior to joining PwC in Luxembourg, he worked in New York and Paris. He regularly participates as a speaker at seminars.

Konstantinos is a Transfer Pricing Director in the Tax team in Luxembourg. He joined PwC Luxembourg in March 2016. In the course of his career, Konstantinos was involved in a large number of projects, such as financing transactions and TP audit support for funds and PE structures, TP aspects of business and debt restructuring, TP policy design and implementation, consulting on infrastructure investment platforms and operational companies reorganisations, etc.