Selected Topics in International Taxation and Transfer Pricing: Principles, Practice and Emerging Trends
This two-day intermediate-level course is designed to equip participants with practical, hands-on insights and comprehensive coverage of the most important issues in international taxation and transfer pricing. Participants will explore Permanent Establishment (PE) rules in practice, examining current approaches, compliance challenges, and real-world scenarios that impact cross-border taxation. The course will also cover treaty anti-abuse rules, highlighting their principles, practical application, and challenges in structuring and compliance. Participants will also gain an in-depth understanding of transfer pricing aspects of intra-group services, including pricing methods, benefit tests, risk allocation, recharacterization, and the burden of proof in audits and disputes.
A major focus will be on the implementation of Pillar Two Global Minimum Tax (GMT rules) and the Qualified Domestic Minimum Top-up Tax (QDMTT), providing practical guidance on domestic compliance, reporting obligations, and strategic considerations in line with the GMT rules.
The course incorporates case studies on selected international tax and transfer pricing issues, enabling participants to apply concepts to real-life situations, strengthen defensible positions, and enhance risk management. By the end of the program, participants will have a holistic understanding of contemporary international tax and transfer pricing challenges and the practical skills to advise their organizations or clients with confidence.
Participants will also have the opportunity to engage with instructors and peers, discussing the practical implications of these developments on businesses, investment flows into Africa, and their day-to-day work.
Claim your 10% early‑bird discount before 30 April 2026. Your discount will be applied automatically at checkout when you register before the deadline.
- Recent International Tax and Transfer Pricing Developments around the Globe – Africa in context
- Tax Treaties: Permanent establishment in practice – current approaches, practical insights and challenges
- Tax Treaties: Anti-Abuse Rules – Principles, application and challenges
- Transfer Pricing: intra-group services, recharacterization and burden of proof
- Pillar Two: Global Minimum Tax – Practical Implementation and Implications for Africa
- Pillar two: GMT – Practical considerations and Key Insights for (Qualified) Domestic Minimum Top Up Tax (QDMTT) Implementation
- Case studies
After this masterclass, the participants will be able to:
- Assess the impact of emerging global tax developments (including BEPS-related initiatives) on existing structures and transactions
- Identify and analyse selected key issues in international taxation and transfer pricing that present heightened risk or planning opportunities
- Understand current interpretation and application of PE concepts, identify common PE risk areas in practice and apply practical strategies to manage PE risk, compliance obligations, and controversy in cross border operations
- Distinguish between key anti-abuse rules and assess their impact on treaty entitlement, structuring and cross border tax planning
- Analyse the TP principles applicable to intra-group services, common risk areas and challenges, how tax authorities may apply recharacterization, and the burden of proof in TP disputes and its implications
- Identify key Pillar Two GMT rules Implementation challenges, including scope determination, income and tax base calculations, and interactions with other GMT rules.
- Analysis how QDMTT interacts with existing domestic tax regimes and investment incentives
- Apply international tax and transfer pricing principles to common cross-border fact patterns
- Birhanu Tadesse Daba, IBFD, the Netherlands
- Carlos Gutiérrez Puente, IBFD, the Netherlands
Other instructors to be listed later
The course is suitable for professionals, such as tax managers and directors, in-house tax/transfer pricing staff and accounting specialists, practitioners in tax advisory firms, and government officials/experts who deal with international tax or transfer pricing in Africa and wish to gain a deeper technical understanding of relevant domestic tax law, tax treaty, and transfer pricing rules and principles in practice and emerging issues thereon.
Sofitel Rabat Jardin des Roses, Rabat, Morocco
This is an intermediary level course. Participants taking this course will be expected to have a good understanding of at least one national tax system, transfer pricing and/or the fundamentals of tax treaties.
International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National. Registry of CPE Sponsors through its website: www.nasbaregistry.org.
In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour. (National Registry of CPE Sponsors ID Number: 107989)
Number of CPE credits: 14
See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or please contact us via email.
- Field of Study - Taxes
- Delivery format: Group Live
- Course level: Intermediate
Please note that the masterclass will take place exclusively in English, without interpretation services.
IBFD reserves the right to cancel this Masterclass up to 14 days before the commencement date.
The programme and line-up of speakers are subject to change.
In the unfortunate event of the masterclass being cancelled, registered participants will receive a credit note by email at the email address provided and a full refund of the masterclass registration fee thereafter. In light of this, participants are kindly advised to make refundable travel and accommodation arrangements. Participants act at their own risk when booking non-refundable travel and accommodation arrangements. IBFD is not responsible for any loss incurred by participants who book non-refundable travel and accommodation arrangements.
All bookings related to travel and accommodation, as well as local transportation, visas, vaccinations and travel insurance are at the participant’s own cost. Registered participants will receive a list of hotels that offer corporate rates.
IBFD offers a group discount on this product. Eligibility is as follows:
For 5–9 registrations in a group, a 5% discount is automatically applied to the order.
For 10 or more registrations in a group, a 10% discount is automatically applied to the order.
