Principles of Tax Transfer Pricing - ATAX0450
Faculty: Australian School of Business
School: Australian School of Taxation and Business Law
Course Outline: ATAX0450 Course Outline
Campus: ATAX Campus
Career: Postgraduate
Units of Credit: 6
EFTSL: 0.12500 (more info)
Indicative Contact Hours per Week: 0
Enrolment Requirements:
Restricted to students enrolled in Programs 9250, 9255, 9260, 9270, 9200, 9210, 9230 or 5740 or 9257 or 9231 or 5231 or 9273
CSS Contribution Charge: 3 (more info)
Tuition Fee: See Tuition Fee Schedule
Further Information: See Class Timetable
View course information for previous years.
Description
This course introduces law, accounting and commerce students to the principles of transfer pricing and its control such as concepts like the arm's length principle. It equips them to identify when there is a risk of a transfer price being challenged and enables them to defend a price that has been set. It imparts a working knowledge of relevant tax rules including the operation of double tax treaties; Advanced Pricing Agreements; OECD guidelines; and applicable anti-avoidance controls. The arm's length pricing methodology is thoroughly analysed for understanding of its application in context of various transactions. Knowledge of tax, especially international tax is assumed.
Recommended Prior Knowledge
International tax
Course Objectives
At the completion of this course students will be able to:
• Explain the operation of the OECD Transfer Pricing Guidelines in international tax
• Explain the arm’s length principle in international transfer pricing
• Explain and apply selected methods of determining an arm’s length price
• Explain the operation of selected national variations transfer pricing rules in international tax
• Identify appropriate methods of setting arm’s length prices and ascertaining comparable in selected transactions
• Adopt and explain various methods of limiting tax risks (such as Advanced Pricing Agreements and Mutual Agreement Procedures) in international transfer pricing
• Explain the operation and effect of transfer pricing rules contained in Double Tax Agreements.
Main Topics
• The Arm’s Length Principles
• Transfer Pricing Methodologies
• Comparability analysis
• Transfer pricing documentation
• Transfer pricing risks management
• Advance Pricing Agreements (APAs) and Cost Contribution Agreements (CCAs)
• Transfer pricing intangibles
• Intra-group services
• Business restructurings (BRs)
• Intra-group finance transactions
Course Texts
Information regarding the Atax Textbook Lists for Semester 1 will be available on the UNSW Bookshop website from 1 February.
Recommended
Refer to Course Profile supplied.
Recommended Prior Knowledge
International tax
Course Objectives
At the completion of this course students will be able to:
• Explain the operation of the OECD Transfer Pricing Guidelines in international tax
• Explain the arm’s length principle in international transfer pricing
• Explain and apply selected methods of determining an arm’s length price
• Explain the operation of selected national variations transfer pricing rules in international tax
• Identify appropriate methods of setting arm’s length prices and ascertaining comparable in selected transactions
• Adopt and explain various methods of limiting tax risks (such as Advanced Pricing Agreements and Mutual Agreement Procedures) in international transfer pricing
• Explain the operation and effect of transfer pricing rules contained in Double Tax Agreements.
Main Topics
• The Arm’s Length Principles
• Transfer Pricing Methodologies
• Comparability analysis
• Transfer pricing documentation
• Transfer pricing risks management
• Advance Pricing Agreements (APAs) and Cost Contribution Agreements (CCAs)
• Transfer pricing intangibles
• Intra-group services
• Business restructurings (BRs)
• Intra-group finance transactions
Course Texts
Information regarding the Atax Textbook Lists for Semester 1 will be available on the UNSW Bookshop website from 1 February.
Recommended
Refer to Course Profile supplied.
Study Levels
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