The module will provide students with knowledge of transfer pricing and the various principles and standards developed to deal with it. There will be a historical overview of the issues followed by an analysis of the evolution of principles leading to the BEPS Action Plan and the updated 2017 Transfer Pricing Guidelines.
The module will consider major current transfer pricing issues around intangibles, business restructuring, the digital economy, services and financing. It also examines issues such as transfer pricing documentation and dispute resolution (both arbitration and litigation). The intersection of transfer pricing with EU law will also be considered and the case law on state aid and APAs will be reviewed in detail.
The course is not jurisdiction specific; rather it offers a holistic approach to the topic with cameos of the different approaches of countries to it.
Final Assessment Exercise