Transfer Pricing course contents table of reading materials by lecture
TRANSFER PRICINGTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More COURSE – Lectures, tutorials, assignments – reading materials
General ongoing reading as the courses advance:
1. reading about 10 pages a week to gain an overview understanding:http://iitfconnect.com/wp-content/uploads/2018/04/An-Overview-of-Transfer-Pricing-by-IBFD.pdf
2. 6 Chapter Transfer Pricing B Arnold International Tax Primer 3rd ed
3. PWC International TP 2015-16:
Part 1: Developing defensible transfer pricing policiesTransfer Pricing Policies refer to the rules and methods established by multinational enterprises (MNEs) to determine the pricing of transactions between related parties, such as subsidiaries or divisions of the same company. These transactions may involve the transfer of goods, services, intellectual property, or financial arrangements. Transfer pricing policies are essential for ensuring that intercompany transactions adhere to the arm’s... More
Introduction……………………………………3
Categories of inter-company transfer…..9
The work of the OECD…………………….25
Establishing a transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More policy – practical considerations………………..47
Specific issues in transfer pricing………71
Managing changes to a transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More policy……………………………….101
Dealing with an audit of transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More by a tax authority………………..115
Financial services………………………….121
Transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More and indirect taxes…..139
Procedures for achieving an offsetting adjustment…………………….157
The OECD’s BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... More Action Plan………….165
5. 11-13 UN Practical Manual on Transfer Pricing for Developing Countries, 2017
Start your Assignment 3 preparation now – start reading the EXTENSIVE DOCUMENTS: the pre-trial filing of Coca-cola to the US tax court, and the long list of supporting articles, and start summarizing the case using the principles in http://iitfconnect.com/wp-content/uploads/2018/04/1-reading-cases-ssrn-id1160925.pdf This may appear as a key exam question as well. The coca-cola case pre-trial document and articles can be found here: http://iitfconnect.com/?p=675
If you want to work through practical problems, a good publication is Elizabeth King, Transfer Pricing and Corporate TaxationCorporate Tax refers to the tax imposed by governments on the income or capital of corporations. Corporations, considered separate legal entities, are taxed on their profits, meaning the income generated from their operational activities, investments, and other financial undertakings. This tax is generally a key revenue source for governments, helping to fund public services, infrastructure, and other essential functions. The... More: Problems, Practical Implications and Proposed Solutions, Kindle edition (2009):Part III Case Studies: https://www.amazon.com/Transfer-Pricing-Corporate-Taxation-Implications-ebook/dp/B001VNC9FE
TRANSFER PRICINGTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More COURSE – Lectures, tutorials, assignments – reading materials
Lecture 1: TP Legal Framework
Lecture 2: TP Legal Framework
Lecture 3: TP Legal Framework
Lecture 4: TP Legal Framework
Lecture 5: ALP and introduction to comparability
Lecture 6: Functional AnalysisFunctional analysis is the cornerstone of transfer pricing and international tax compliance, ensuring that intercompany transactions adhere to the arm’s length principle. It evaluates the roles, contributions, and risk profiles of entities within a multinational enterprise (MNE) to determine how profits and costs should be allocated. This process ensures that related-party transactions reflect the pricing that independent enterprises would establish... More
Lecture 7: TP Methods
Lecture 8: TP Methods
Lecture 9: TP Methods
Lecture 10: Comparability AnalysisA Comparability Analysis is an essential framework in Transfer Pricing used to evaluate whether the conditions of a transaction between related entities (such as subsidiaries of the same multinational enterprise) are consistent with the arm’s length principle. The arm’s length principle requires that intercompany transactions reflect terms that independent entities would negotiate under comparable circumstances, ensuring that multinational corporations (MNEs)... More Part I
Lecture 11: Comparability AnalysisA Comparability Analysis is an essential framework in Transfer Pricing used to evaluate whether the conditions of a transaction between related entities (such as subsidiaries of the same multinational enterprise) are consistent with the arm’s length principle. The arm’s length principle requires that intercompany transactions reflect terms that independent entities would negotiate under comparable circumstances, ensuring that multinational corporations (MNEs)... More Part II
Lecture 12: Comparability AnalysisA Comparability Analysis is an essential framework in Transfer Pricing used to evaluate whether the conditions of a transaction between related entities (such as subsidiaries of the same multinational enterprise) are consistent with the arm’s length principle. The arm’s length principle requires that intercompany transactions reflect terms that independent entities would negotiate under comparable circumstances, ensuring that multinational corporations (MNEs)... More Part III
Lecture 13: Intra-group ServicesFOR MORE INSIGHT ON INTRA-GROUP SERVICES, PLEASE READ THIS ARTICLE: Intra-Group Services: Guidelines, Examples, and Risk Management Strategies Intra-Group Services refer to activities performed by one entity within a multinational enterprise (MNE) group that benefit one or more associated enterprises. These services may include administrative, technical, financial, or commercial assistance provided by a central company to its affiliates. A primary... More Part I
Lecture 14: Intra-group ServicesFOR MORE INSIGHT ON INTRA-GROUP SERVICES, PLEASE READ THIS ARTICLE: Intra-Group Services: Guidelines, Examples, and Risk Management Strategies Intra-Group Services refer to activities performed by one entity within a multinational enterprise (MNE) group that benefit one or more associated enterprises. These services may include administrative, technical, financial, or commercial assistance provided by a central company to its affiliates. A primary... More Part II
Lecture 15: Intangibles Part 1
Lecture 16: Intangibles Part II
Lecture 17: Intangibles Part III
Lecture 18: Cost contribution arrangements
Lecture 19: Cost contribution arrangements
Lecture 20: Financing I
Lecture 21: Financing II
Lecture 22 and 23: Business Restructuring I & II
Lecture 24 and 25: Permanent Establishments I & II
Lecture 26 and 27: Compliance Part I & II
Lecture 28: Dispute
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