TP Lecture week 5 – ALP and introduction to comparability
Follow curriculum – Reading:
OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017
Chapter 1: Section A-C
| Introduction……………………………………3 |
| Categories of inter-company transfer…..9 |
| The work of the OECD…………………….25 |
| 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... 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... 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... and indirect taxes…..139 |
| Procedures for achieving an offsetting adjustment…………………….157 |
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: thepre-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
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