Course Aims:
The aim of this module is to ensure a student understands how certain of the more complex type of TP transactions are to be identified, treated, analysed and priced in terms of the OECD guidelines.
The module aims to provide sufficient guidance to a student to identify Intangible transactions, their owners, how these are to be priced, how the transfer of intangibles is to be treated & priced and allocations to be made based upon the OECD guidelines and the arm’s length principle.
The module aims to provide the student with a detailed understanding of cost contribution arrangements, the application of the arm’s length principle to such arrangements and how adjustments are to be made.
The module aims to provide an understanding of the various types of financial transactions in a TP environment including cash pooling and provides guidance on how to price such transactions on an arm’s length charge.
When the course is complete the student will be able to:
1. Identify intangible transactions for transfer pricing purposes as per the OECD Guidelines.
2. Review the general issue of entities joining or leaving a Cost Contribution Arrangement (CCA).
3. Outline the various types of inter-company financial transactions (including cash pooling).
4. Distinguish cost contribution arrangements from other transactions.
5. Recognise whether the conditions established by associated enterprises for transactions covered by a CCA are consistent with the arm’s length principle.
COURSE NOTE:
This course is Module 2 of a 4 Module course on Transfer Pricing. Each Module stands separately, however, we suggest that you complete all 4 courses in order to get the full benefit of these teachings.
Additional Modules in the whole course are:
Module 1 - Transfer Pricing Legal Framework
Module 2 (this course) - Sharing Corporate Resources
Module 3 - Transfer Pricing Specialised Areas
Module 4 - PE's & Compliance and Dispute Resolution
