Global Practice

Transfer pricing advisory, training & research

Helping multinationals navigate transfer pricing — through advisory, published research, and structured training programmes.

Books & Courses

Published Work and Training Programmes

Book
Decoding the Arm's Length Principle

An examination of the arm's length standard — its commercial rationality foundations, post-BEPS evolution, and practical application in transfer pricing disputes and policy design.

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Book
NRI MiTRA

The definitive guide to tax and regulatory aspects of investing, banking, and financial planning for Non-Resident Indians — covering FEMA, DTAA, and compliance essentials.

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Diploma Course
Diploma in Transfer Pricing — Kaplan MENA

Exclusive educator for Kaplan MENA's TP Diploma. Covers OECD Guidelines, regulations, documentation, benchmarking, and practical case studies for working professionals.

Learn More at Kaplan
Online Course
Value Chain Analysis, TP Policy & Operational TP

Self-paced Udemy course covering global value chain analysis, designing transfer pricing policies, and implementing operational TP — with real-world case studies and downloadable resources.

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Strategic Foresight in Transfer Pricing

Published in IBFD International Transfer Pricing Journal — pioneering research on integrating strategic foresight into TP practice.

AI-Driven Economies & Transfer Pricing

IJRASET published research on implications of AI-driven economic models for transfer pricing frameworks. ICAI Research Award winner.

Now Enrolling

ADIT Exam Preparation Programme

Structured exam preparation for the CIOT's Advanced Diploma in International Taxation — covering Paper 1 (Principles of International Taxation) and Paper 3.03 (Transfer Pricing). Available as recorded self-study and live interactive sessions.

P1

Principles of International Taxation

Paper 1 — Mandatory Module

Comprehensive coverage of the OECD and UN Model Tax Conventions, treaty interpretation, residence rules, and the full spectrum of cross-border taxation principles required for the compulsory ADIT paper.

01 Sources and Principles of International Tax Law
02 Tax Residence — Individuals and Corporates
03 OECD and UN Model Tax Conventions
04 Treaty Interpretation — Vienna Convention
05 Business Profits and Permanent Establishments
06 Taxation of Passive Income — Dividends, Interest, Royalties
07 Capital Gains and Employment Income
08 Transfer Pricing under Tax Treaties
09 Double Taxation Relief Mechanisms
10 International Tax Avoidance and Anti-Abuse
11 BEPS Action Plans and Multilateral Instrument
12 Pillar One, Pillar Two and the Global Minimum Tax
13 Exchange of Information and MAP
14 Exam Technique — Essay and Scenario Questions
3hr 15min exam June & December sittings ~140 hours study time
P3

Transfer Pricing

Paper 3.03 — Thematic Option

Deep dive into transfer pricing methods, the arm's length principle, OECD Guidelines, functional analysis, comparability, intangibles, financial transactions, and dispute resolution — mapped to the 2026 CIOT syllabus.

01 Arm's Length Principle and Commercial Rationality
02 Functional Analysis and Value Drivers
03 Comparability Analysis and Benchmarking
04 TP Methods — Traditional and Profit-Based
05 Intangibles — DEMPE and Hard-to-Value
06 Intra-Group Services and Cost Contribution
07 Financial Transactions — Loans, Guarantees, Captives
08 Business Restructurings and Profit Allocation
09 PE Profit Attribution — AOA
10 Compliance, Documentation and CbCR
11 Dispute Resolution — MAP and APA
12 UN Practical Manual and Developing Countries
13 BEPS Actions 8–10, 13 and Amount B
14 Exam Technique — Case Studies and Analysis
3hr 15min exam June & December sittings Parts A, B & C format
How You'll Learn

Choose Your Format

Live Interactive Cohort

Join a guided cohort with live sessions, Q&A, exam strategy coaching, and direct access to the instructor.

  • Weekly live classes with real-time Q&A
  • Small cohort for personalised attention
  • Exam technique workshops with timed practice
  • Session recordings if you miss a class
  • Direct instructor support via dedicated group
Why This Programme

What You Get From a Practitioner, Not Just a Tutor

Taught by an Active TP Practitioner

14+ years of Big 4 transfer pricing experience across PwC and KPMG — real engagements, real disputes, real advisory work informing every lecture.

ADIT Qualified, Both Papers

Passed Paper I and Paper III personally. Knows the exam from the inside — what the examiners expect, how marks are allocated, where candidates lose points.

Published Researcher

IBFD International Transfer Pricing Journal author. Brings academic depth and OECD policy understanding beyond textbook coverage.

Exam-Focused Methodology

Past paper analysis, model answer frameworks, time management strategies, and writing techniques designed to maximise marks.

Real-World Case Integration

Every module connects theory to practical scenarios — MNE structures, TP disputes, treaty application — not just abstract principles.

Flexible and Global Access

Study from anywhere — recordings accessible on demand, live sessions in timezone-friendly slots, designed for working professionals.

Register Your Interest

Enrolment is opening soon. Register below to receive early access, course details, and pricing when the programme launches.

Advisory Services

Transfer Pricing and International Tax

Practical, defensible solutions across the full TP lifecycle.

TP Advisory & Documentation

Benchmarking, documentation, policy design, and intercompany agreement structuring for MNEs.

Value Chain Analysis

Business operations analysis, profit driver mapping, and value creation alignment with TP outcomes.

Dispute Resolution

Representation in TP audits, disputes, and MAP proceedings grounded in OECD Guidelines.

Cross-Border Restructuring

Business model realignment, supply chain redesign, and tax-efficient restructuring.

Operational Transfer Pricing

Bridging policy and execution — process mapping, real-time implementation, and compliance management.

International Tax Planning

Holding structures, WHT optimisation, and cross-border strategy across India, UK, the Middle East, and beyond.

About

Ajit Jain

I am a Partner and the Head of Transfer Pricing at AJMS Global. Over a career spanning more than 14 years, I have worked on transfer pricing and international tax engagements for multinational enterprises across sectors including Oil and Gas, Pharmaceutical, FMCG, Engineering, IT, and Logistics. My work covers advisory, litigation support, policy design, and operational transfer pricing implementation.

I hold dual Chartered Accountant qualifications from ICAEW (UK) and ICAI (India), alongside a Company Secretary qualification, ADIT (Papers I and III), a Diploma in Tax Technology from CIOT (UK), and Alteryx Designer certification. I am the exclusive educator for Kaplan MENA's Diploma in Transfer Pricing and have published research in the IBFD International Transfer Pricing Journal and IJRASET.

Outside of advisory work, I am a published author, Udemy course instructor, and a regular speaker at professional forums. I believe in making transfer pricing accessible, practical, and grounded in economic reality.

CA (ICAEW, UK) CA (ICAI, India) ADIT (I & III) Company Secretary Diploma in Tax Technology Alteryx Designer Certified BFP, UK
Recognition
2025 TP Consultant of the Year — Bconnect Global
2025 ICAI International Research Award
2024 LinkedIn Top Voice — Transfer Pricing
2020 ICAI International Research Award

Industries

Oil & Gas Engineering Pharma FMCG Media Logistics Construction IT & Telecom

Speaking

ICAI International Chapter Taxation Society CTC Mumbai FinTEdu
FAQ

Common Questions

I provide end-to-end TP advisory — documentation, benchmarking, policy design, value chain analysis, dispute resolution, APA support, and operational TP implementation for multinational enterprises across the Middle East, India, UK, and beyond.
Yes. I deliver training through Kaplan MENA's Diploma in Transfer Pricing, Udemy courses on Value Chain Analysis and Operational TP, and bespoke corporate workshops on OECD Guidelines and international tax regulations.
Oil and Gas, Engineering, Pharmaceutical, FMCG, Construction, Entertainment and Media, Logistics, IT, and Telecom — across cross-border engagements of varying scale.
I am based in Global Practice, covering the Middle East (including GCC), India, the UK, and international cross-border engagements.
Dual CA (ICAEW UK and ICAI India), Company Secretary, ADIT (Papers I & III), Diploma in Tax Technology (UK), BFP (UK), and Alteryx Designer Certified.
Get in Touch

Let's discuss your requirements

Whether you need advisory support, training for your team, or are exploring a speaking engagement — I would be happy to hear from you.

International Practice