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Advanced Diploma – Transfer Pricing Curriculum and reading materials

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Curriculum – AD Transfer Pricing 2018 vr6

Please note that the tutorial questions and the assignments are embedded in the Curriculum Spreadsheet with hyperlinks to make it easier to prepare. But the essential reading materials are set out below, with addition up-to-date reading you should be doing as changes are made by the OECD and other bodies/institutions (see Latest updated reading materials):

Reading materials per lecture – http://iitfconnect.com/?p=1043

Latest updated reading materials:

http://iitfconnect.com/?p=1440

Prescribed reading:

A Practical Summary of the 2017 OECD TPG –  https://www.dropbox.com/s/ynsl1x2h3sk037e/A{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20practical{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20summary{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20of{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20the{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20July{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202017{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20OECD{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Johann{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20H.pdf?dl=0

6 Chapter Transfer Pricing B Arnold International Tax Primer 3rd ed

8 Chapter An introduction to Tax Treaties

An Overview of Transfer Pricing by IBFD

OECD Income and Capital Model Convention and Commentary 2017

OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017

UN TPG 2017 for download – http://192.168.1.1:8181/http://www.un.org/esa/ffd/wp-content/uploads/2017/04/Manual-TP-2017.pdf

PWC International TP 2015-16

TPA Country summaries library: https://www.tpa-global.com/dv/page23901/country-summaries

TP cases to consider:

http://iitfconnect.com/?p=1600

Tax Risk Management is an important process you must implement for TP clients. Here are the required reading materials, on which you will be examined. This information covers ethical and management issues you must be aware of, which are discussed from time-to-time in the lectures:

The Tax Risk Management pdf copy handbook “Tax Intelligence”:

http://taxriskmanagement.com/wp-content/uploads/2018/03/a-Tax-Intelligence-The-7-Habitual-Tax-Mistakes-Made-by-Companies-updated-26-Jan-2018.pdf

Here is the summary book:

http://taxriskmanagement.com/wp-content/uploads/2018/03/7-Habitual-Tax-Mistakes-updated-26-Jan-2018.pdf

Here is a tax risk management plan template, based on our one project in Hungary for a MNE:

TRM Policy Document PRECEDENT General with Hungary – case study

This can be used by you in formulating a TRM plan for TP clients.

 

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Choose the track that fits your practice focus. All programmes are practitioner-taught, cohort-based, and validated by Middlesex University.

Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
Entry point Start with PG Certificate, progress to PG Diploma, then MSc, or enter later with suitable experience or credits.

Awards Ladder

Award Best for What you achieve Assessment highlights
PG Certificate Foundation to intermediate upskilling Core concepts, frameworks, and applied techniques Short case write ups, timed responses, applied tasks
PG Diploma Expanding technical depth and application Advanced analysis, risk management, documentation quality Integrated case assignments, policy memos, oral defence
MSc Leaders and specialists building authority Capstone project and research backed practice outcomes Research project, viva or presentation, publishable summary

IFF Certificate Courses

Practical, practitioner-led certificates designed for immediate on-the-job application. Each course can stand alone or act as a pathway into our postgraduate tracks.

Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
Core focus Case theory, evidence files, expert reports, witness prep, courtroom strategy Operating models, KPIs, workflows, stakeholder management, coaching VAT design, place of supply, input credits, exemptions, WHT interactions Risk identification, controls, documentation, audit readiness, dispute playbooks
Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
Duration 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time
Outcomes Confident litigation preparation and defence for TP disputes Stronger execution, clear roles, measurable team performance Reduced VAT errors, better cash flow, fewer surprises at audit Structured governance, fewer findings, faster dispute resolution
Prerequisites TP fundamentals recommended Supervisory experience helpful Basic VAT knowledge helpful General tax experience helpful
Pathway Progress to PG Certificate in Transfer Pricing Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) Progress to PG programmes, International Tax or SA Tax Law Progress to PG Certificate in International Taxation or Transfer Pricing
Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected