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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 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.

On successful completion of this module, the student should 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 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 – Transfer Pricing Legal Framework
  • Module 2  – Sharing Corporate Resources
  • Module 3 (This Course) – Transfer Pricing Specialised Areas
  • Module 4 – PE’s & Compliance and Dispute Resolution

 

Course Curriculum

Introduction
Course Resource Material 00:30:00
Lecture 1 - Intangibles (Part 1)
Part 1 – Identifying Intangibles 00:19:37
Part 2 – Valuation of Intangibles 00:38:55
Part 3 – OECD Examples 00:12:14
Lecture 2 - Intangibles (Part 2)
Part 1 – Function 00:18:46
Part 2 – Assets and Risk 00:15:04
Part 3 – Intangibles: Specific Situations 00:39:20
Lecture 3 - Intangibles (Part 3)
Part 1 – Transfer of Intangibles 00:19:32
Part 2 – Transactions involving the use of Intangibles 00:26:24
Part 3 – Intangibles: more detail 00:25:54
EXAMPLE: Royalty Stat Presentation 00:29:33
Lecture 4- Cost Contribution Arrangements (Part 1)
Part 1 – Concepts of CCA part 1 00:14:00
Part 2 – Concepts of CCA part 2 00:13:42
Part 3 – Concepts of CCA part 3 00:09:56
Lecture 4- Cost Contribution Arrangements (Part 2)
Part 1 – Applying the ALP 00:11:51
Part 2 – Delineation and final notes 00:16:58
Lecture 5 - Financing (Part 1)
Part 1 – Background on Financial Transactions 00:12:27
Part 2 – Guidance Available 00:36:25
Part 3 Intra-Group loans, Financing & Guarantees 00:23:55
Lecture 6 - Financing (Part 2)
Part 1 – Recap of lecture 19 00:11:47
Part 2 – Cash Management (Pooling) 00:25:20
Part 3- Deeper into financing 00:30:38
Part 4 – Compiling Policies 00:06:08

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