IIRF Online > Finance & Accounting > Taxes > Transfer Pricing > Transfer Pricing Masterclass (Part 1)
Transfer Pricing Masterclass (Part 1) by Udemy
TP Legal Framework
Course Highlights
- 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 to 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 provide a critical outline of the vsteps required to conduct a Functional Analysis.
Skills you will learn!
Curriculum
1 Topic
Introduction
7 Topics
TP Legal Framework - Part 1: Back Ground to legal Systems
TP Legal Framework - Part 2 - Finding Case Law online
TP Legal Framework - Part 3 - Double Tax Treaties/ Agreements
TP Legal Framework - Part 4 - OECD TP Guidelines & UN Practical TP
TP Legal Framework - Part 5 - In-country legislation
TP Legal Framework - Part 6 - Other treaties & legislation
Extra Lecture - Disputes Adjustments & Cases
7 Topics
Part 1 - Introduction
Part 2 - US Cases
Part 3 - Canadian Cases
Part 4 - Indian Cases
Part 5 - Brazilian Cases
Part 6 - African Cases
Part 7 - DTA's
4 Topics
Part 1 - Introduction & Turkey (Pt1)
Part 2 - Turkey (Pt2)
Part 3 - Kenya (Pt1)
Part 3 - Kenya (Pt2)
3 Topics
Part 1 - Rationale Definition & Source
Part 2 - Example Weakness & The Future
Part 3 - Comparables
3 Topics
Part 1 - Introduction
Part 2 - Analysis of risk
Part 3 - Examples
Transfer Pricing Masterclass (Part 1)
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