Transfer Pricing
NOTE: The following course description is PRELIMINARY and ILLUSTRATIVE. The details of the teaching arrangements as well as the contents of the course have not yet been finalised and students should not make plans based on this description.
Elective
The Transfer Pricing course provides an overview of transfer pricing 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. The course draws from areas such as economics, taxation, law, accounting, management and finance to emphasis the multidisciplinary nature of transfer pricing.
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
- Financing
- Intangible property
- Business restructurings
- Permanent Establishments
- Compliance issues
- Avoiding Double Taxation/Dispute Resolution
The course is taught by Dr Richard Collier, PWC and Dr Glen Loutzenhiser