Transfer Pricing: Practice and Problems

Subject 730-834 (2009)

Note: This is an archived Handbook entry from 2009. Search for this in the current handbook

Credit Points:
Level: Graduate/Postgraduate
Dates & Locations:

This subject has the following teaching availabilities in 2009:

November, - Taught on campus.
Pre-teaching Period Start not applicable
Teaching Period not applicable
Assessment Period End not applicable
Last date to Self-Enrol not applicable
Census Date not applicable
Last date to Withdraw without fail not applicable


Timetable can be viewed here. For information about these dates, click here.
Time Commitment: Contact Hours: 24 - 26 contact hours per subject.
Total Time Commitment: The time commitment for this subject depends on the candidates background and experience.
Prerequisites: N.A.
Corequisites: N.A.
Recommended Background Knowledge: None
Non Allowed Subjects: None
Core Participation Requirements: N.A.

Coordinator

Dr Michael Kobetsky
Subject Overview:

Objectives:

This subject provides an introduction to the OECD Transfer Pricing Guidelines, Australian transfer pricing rules and practical case studies.

International transfer pricing is the price charged for the transfer of property or services between associated entities in an international company group. Transfer pricing is consistently identified in international surveys of multinational enterprises as the most important tax issue they face. Multinational enterprises have to deal with demands from the various jurisdictions in which they operate as national tax agencies implement measures to protect their revenue from cross-border trade between associated entities. Multinational enterprises often incur significant costs in complying with domestic tax rules.

This subject is designed for both transfer pricing advisers and tax advisers.

 


Syllabus:

Principal topics will include:

  • Legal framework around transfer pricing:
    • OECD guidelines on transfer pricing
    • Australia’s tax legislation and tax rulings on transfer pricing
    • Australia’s tax treaties and transfer pricing
    • Case law in Australia and overseas
  • Transfer pricing methodologies – selection and application for the following transactions:
    •  Tangible goods
    • Intangibles
    • Services
    • Financing transactions
  • Transfer pricing documentation requirements
  • Performing a comparable search (benchmarking)
  • Completing the transfer pricing section of the tax return (Schedule 25A)
  • Transfer pricing controversy:
    • Risk reviews and audit approach
    • Advance pricing arrangements
Assessment:
  • Class participation (10%)
  • Class assignment (30%)
  • Take-home examination (60%) (29 January–1 February 2010)
    or
    Research paper 6,000 words (60%) (25 February 2010) (topic approved by the subject coordinator)

 
Prescribed Texts: Core subject materials will be provided free of charge to all students. Some subjects require further texts to be purchased. Please visit the subject homepage on the Melbourne Law Masters website by following the link at the bottom of this subject entry.
Breadth Options:

This subject is not available as a breadth subject.
Fees Information: Subject EFTSL, Level, Discipline & Census Date
Generic Skills: Please see the Subject Objectives for this information.
Links to further information: 730-834Transfer Pricing: Practice and ProblemsMelbourne Law Masters, postgraduate law, post-graduate law, graduate law2009P

Objectives:

This subject provides an introduction to the OECD Transfer Pricing Guidelines, Australian transfer pricing rules and practical case studies.

International transfer pricing is the price charged for the transfer of property or services between associated entities in an international company group. Transfer pricing is consistently identified in international surveys of multinational enterprises as the most important tax issue they face. Multinational enterprises have to deal with demands from the various jurisdictions in which they operate as national tax agencies implement measures to protect their revenue from cross-border trade between associated entities. Multinational enterprises often incur significant costs in complying with domestic tax rules.

This subject is designed for both transfer pricing advisers and tax advisers.

 


Syllabus:

Principal topics will include:

  • Legal framework around transfer pricing:
    • OECD guidelines on transfer pricing
    • Australia’s tax legislation and tax rulings on transfer pricing
    • Australia’s tax treaties and transfer pricing
    • Case law in Australia and overseas
  • Transfer pricing methodologies – selection and application for the following transactions:
    •  Tangible goods
    • Intangibles
    • Services
    • Financing transactions
  • Transfer pricing documentation requirements
  • Performing a comparable search (benchmarking)
  • Completing the transfer pricing section of the tax return (Schedule 25A)
  • Transfer pricing controversy:
    • Risk reviews and audit approach
    • Advance pricing arrangements
  • Class participation (10%)
  • Class assignment (30%)
  • Take-home examination (60%) (29 January–1 February 2010)
    or
    Research paper 6,000 words (60%) (25 February 2010) (topic approved by the subject coordinator)

 

N.A. N.A.24 - 26 contact hours per subject.Core subject materials will be provided free of charge to all students. Some subjects require further texts to be purchased. Please visit the subject homepage on the Melbourne Law Masters website by following the link at the bottom of this subject entry.Please see the Subject Objectives for this information.The time commitment for this subject depends on the candidates background and experience.N.A.Please see the subject homepage on the Melbourne Law Masters website for up to date timetable information.Dr Michael KobetskyLawLawNNNNParkvillePARKVILLEFor the latest information on this subject, please visit: http://www.masters.law.unimelb.edu.au/subject/730834730-8342November

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