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The 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.

COURSE NOTE:

This course is Module 1 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(this course) – Transfer Pricing Legal Framework
  • Module 2  – Sharing Corporate Resources
  • Module 3 – Transfer Pricing Specialised Areas
  • Module 4 – PE’s & Compliance and Dispute Resolution

Course Curriculum

Introduction
Introduction 00:30:00
Lecture 1 - TP Legal Framework, An Introduction
Part 1 – Back Ground to Legal Systems 00:20:00
Part 2 – Finding Case Law online 00:05:30
Part 3 – Double Tax Treaties 00:21:45
Part 4 – OECD TP Guidelines & UN Practical TP 00:02:21
Part 5 – In Country Legislation 00:02:32
Part 6 – Other treaties & Legislation 00:09:49
EXTRA LECTURE – Disputes, Adjustments & Cases 00:58:28
Lecture 2 - Overview of important TP cases
Part 1 – Introduction 00:02:08
Part 2 – US Cases 00:16:48
Part 3 – Canadian Cases 00:08:39
Part 4 – Indian Cases 00:07:15
Part 5 – Brazilian Cases 00:03:45
Part 6 – African Cases 00:15:40
Part 7 – DTA’s 00:02:36
Lecture 3 - Country Legislation Examples
Part 1 – Intro & Turkey (Part 1) 00:14:13
Part 2 – Turkey (Part 2) 00:15:15
Part 3 – Kenya (Part 1) 00:13:05
Part 4 – Kenya (Part 4) 00:17:49
Lecture 4 - Arm's Length Principle
Part 1 – Rationale, Definition & Source 00:16:38
Part 2 – Example, Weakness & the future 00:13:20
Part 3 – Comparables 00:16:50
Lecture 5 - Functional Analysis
Part 1 – Introduction 00:12:36
Part 2 – Analysis of Risk 00:16:37
Part 3 – Examples 00:19:17

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