Rating 3.45 out of 5 (41 ratings in Udemy)
What you'll learn- Legal Framework
- Arm's Length Principle
- Functional Analysis
- Identify and explain how transfer pricing impacts companies with multinational operations.
- Describe and illustrate the ethical and moral issues raised by present-day transfer pricing practices.
- Critically evaluate and compare different transfer pricing rules and regulations in key countries.
- Deal with complex legal concepts and key case law related to Transfer …
Rating 3.45 out of 5 (41 ratings in Udemy)
What you'll learn- Legal Framework
- Arm's Length Principle
- Functional Analysis
- Identify and explain how transfer pricing impacts companies with multinational operations.
- Describe and illustrate the ethical and moral issues raised by present-day transfer pricing practices.
- Critically evaluate and compare different transfer pricing rules and regulations in key countries.
- Deal with complex legal concepts and key case law related to Transfer Pricing.
- Explain and critique sections relating to Transfer Pricing within the United Nations and OECD Model Tax Convention, with specific reference to Articles 7, 9, 10, 11 and 12.
- Analyse, critically reflect on and synthesise complex concepts relating to the Arm’s length principle.
- Explain the term, Functional Analysis, as set out in the OECD Guidelines and be able to provide a critical outline of the various steps required to conduct a Functional Analysis.
DescriptionThe aim of this module is to highlight the legal framework that covers Transfer Pricing. Transfer Pricing touches multinational corporations, working in multiple jurisdictions. This module will provide the student with an overview of the tools needed to assess the the legal environment of a specific jurisdiction when applying the transfer pricing principles. This is a very broad module, however, it lays the foundation for the rest of the course. The appreciation of operating within an ethical framework and specifically within the Transfer Pricing environment is discussed with the students.
The module also covers the very important Arm’s Length Principle and Functional Analysis, laying further groundwork for the rest of the course.
The "Arm's-Length Principle" of transfer pricing states that the amount charged by one related party to another for a given product must be the same as if the parties were not related. An arm's-length price for a transaction is therefore what the price of that transaction would be on the open market.
The functional analysis is used for transfer pricing purposes. It analyses the functions performed (taking into account assets used and risks assumed) by associated enterprises in a transaction.
