Transfer Pricing & Related-Party Transactions
Defend intercompany pricing to tax authorities with documentation, benchmarking and substance that survives audit.
The executive challenge
The problem this program solves
Your institution still earns most of its margin from products the mobile rails have commoditised, and the board is asking what transfer pricing changes about that — this year. Every partnership signed without governance economics becomes a renegotiation you conduct from weakness. You will stress-test your own institution in the IPAT Data Lab™ and leave with a transfer pricing strategy that survives both a supervisor and a competitor.
Context
Why this matters now
Capability
What you will be able to do
- Diagnose where your institution creates — and destroys — value in transfer pricing across the balance sheet.
- Present a transfer pricing position to boards and supervisors with evidence they will accept.
- Read the economics of transfer pricing like an operator: unit costs, network effects and risk-adjusted return.
- Sequence a transfer pricing transformation agenda that a board will fund and a regulator will endorse.
The IPAT Course Standard
The five-day journey
Each day is a deliberate progression in managerial capability — from strategic context, to analytical frameworks, to applied practice, to executive judgement under pressure, to a capstone that produces something your organisation keeps.
IPAT Signature Case™
The Margin That Walked
The most profitable product at a tier-two African bank has quietly migrated to instant-payment rails the institution does not own; deposits follow the customer, not the branch. The board wants a response before the next pricing cycle — and the transfer pricing data is contested in every committee.
Your decision: Build competing rails, partner with the platform, or reprice the legacy book to defend margin — each path changes the institution you become.
IPAT Data Lab™
The transfer pricing unit economics at a development finance institution work in the business case and fail in the ledger.
Dataset: Synthetic product-level revenue, cost and capital data for a development finance institution.
Your task: Rebuild the unit economics, stress them against rate and funding shocks, and recommend what to scale or exit.
A stress-tested transfer pricing economics model and a board-grade summary page.
Data → Analysis → Decision, not Data → Code → Certificate
Day 5 · The Capstone
What will you change when you return to work?
Produce a digital finance transformation strategy for your institution: where to play, what to own, which partnerships, and the regulatory posture required.
Methodology
Frameworks you will master
- • IPAT Decision Intelligence Framework™
- • IPAT Transformation Architecture™
- • Value-chain decomposition
- • Risk-adjusted performance measurement (RAROC)
- • Basel-aligned capital and liquidity concepts
Cohorts
Upcoming cohorts
New dates are being scheduled
Register with your preferred start date and our admissions team will match you to the next available cohort — or contact us to arrange an in-house delivery for your organisation.
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