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Transfer Pricing: Practice and Problems 730834

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