TP Lecture week 12 – Comparability analysis Part III

ATL-Editor 18 April 2018

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Follow curriculum – Reading:

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

Chapter III: Part A6

General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of Transfer Pricing by IBFD

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 1 Reading cases SSRN-id1160925 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

Categories: Africa, FP News, Nigeria, SADC, South Africa, West Africa, Zambia

Tags: Courses, transfer pricing

ATL-Editor

Guide to Comparability Analysis in Transfer Pricing

Understand comparability analysis in transfer pricing with this comprehensive guide. Learn the steps, factors, and best practices for conducting a robust analysis.

Dr Daniel N Erasmus 20 June 2024

Transfer Pricing course contents table of reading materials by lecture

TRANSFER PRICING COURSE – Lectures, tutorials, assignments – reading materials General ongoing reading as the courses advance: 1. reading about 10 pages a week to gain an overview

ATL-Editor 20 April 2018

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AFRICA: Sub-Saharan Africa and international arbitration – how does that work?

COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take a look at the following

ATL-Editor 29 August 2014

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Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute

The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The case centers on the appropriate transfer pricing method to allocate profits between Coca-Cola’s U.S. parent company and its foreign subsidiaries. The IRS argued that Coca-Cola’s existing transfer pricing method resulted in underpayment of U.S. taxes, leading to a significant tax deficiency.

Dr Daniel N Erasmus 18 November 2020

Cook Islands: FATCA’s impact – this paper applies to many other offshore centres

April/May 2015[1] Impact of FATCA on Cook Islands Entities[2] TABLE OF CONTENTS Background The key differences between FATCA and IGA Models 1 and 2

ATL-Editor 27 April 2015

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