Transfer Pricing

Elective

Problems in transfer pricing and profit attribution.

The Transfer Pricing course is concerned with the arm’s length principle and its application in the form of transfer pricing and profit attribution rules. The course provides an overview of transfer pricing and profit attribution from both a theoretical and practical perspective using case studies to illustrate the key principles, with a focus on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the OECD’s guidance on PE attribution including the 2010 Report on the Attribution of Profits to Permanent Establishments. The course will consider the current debate on transfer pricing and profit attribution with a number of topical examples and the major conceptual, technical and practical problems of the income allocation rules will also be an especial area of focus.

The course includes the following topics:

Fundamental Sources
The Arm’s Length Principle and Comparability
Functional Analysis
Transfer Pricing Methods
Comparability analyses in practice
Intra-group services
Risk and capital
Issues raised by minimal function entities
Financing
Intangible property
Business restructurings
Permanent Establishments
Compliance issues
Avoiding Double Taxation/Dispute Resolution
The future of the income allocation rules/arm’s length principle

The course is taught by Dr Richard Collier, Associate Fellow at Saïd Business School and Professor John Vella