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 pricing policy……………………………….101 |
Dealing with an audit of transfer pricing by a tax authority………………..115 |
Financial services………………………….121 |
Transfer pricing 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
Responses