What you'll learn
Arm's Length Principle
Comparability Analysis
Transfer Pricing Methods
Transfer Pricing Documentation
Dispute Resolution
OECD Guidelines
Requirements
Understanding of the basic corporate tax and international tax concepts is needed.
Description
Transfer pricing is one of the most interesting areas in international taxation. Tax professionals, economists, lawyers, and finance professionals enjoy its application as it allows them to study the global business and legal structure of multinational enterprises.
This course is on the "arm's length principle" and its application.
After this course, it will be easier for you to understand the relevant chapters of the OECD's TP Guidelines.
Reading the guidelines will make you familiar with its language, and once you are comfortable with it, you will start enjoying reading the relevant case laws and literature on transfer pricing.
After understanding the core concepts of the "arm's length principle" thoroughly, you will enjoy the process of transfer pricing analysis and the application of the arm's length principle, controversies around it, case laws, development in the rules and regulations globally, debates and opinions, etc.
Course outline
I have provided an overview of the course in the first couple of videos. It will help in tracking your progress and having an overall sense of direction.
It starts with the basic statement on the arm's length principle (ALP) provided in article 9 of the Model Tax Convention issued by the OECD. It then covers the OECD's guidance contained in its "Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations" on the application of the ALP, using the suggested nine-step process of comparability analysis, documentation, and dispute resolution.
Big picture - an overview of the arm's length principle and comparability analysis
Simple Example to provide a basic background for the course
Arm's Length Principle - Article 9 of the OECD's Model Tax Convention
Guidance on the application of the arm's length principle
Identification of the commercial and financial conditions of the controlled and uncontrolled transactions
The contractual terms of the transactions
Functional Analysis
Analysis of risks in commercial and financial conditions
Risk-free and risk-adjusted rates of return
Economic circumstance
Business strategies
Transfer Pricing Methods
Selection of the most appropriate transfer pricing method
Examples of how TP methods are selected in various intra-group transactions to
Five suggested TP methods
Comparability Analysis - The suggested nine-step process
Transfer Pricing Documentation
Country-by-country reporting
Master File
Local File
Who this course is for
Tax professionals and government tax officials
Finance and accounting professionals
Economists intending to have introduction to transfer pricing
Legal professional in international tax practice
Homepage

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