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Principles of Tax Transfer Pricing - ATAX0450
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Faculty: Australian School of Business
 
 
School:  Australian School of Taxation and Business Law
 
 
Course Outline: See below
 
 
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:Band 3 (more info)
 
 
Tuition Fee:See Tuition Fee Schedule
 
 
Further Information: See Class Timetable
 
 

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

Assessment

1 Research paper (+ Plan)

1 Exam

Course Texts

Prescribed

Information regarding the Atax Textbook Lists for Semester 1 will be available on the UNSW Bookshop website from 1 February.

Information regarding the Atax Textbook Lists for Semester 2 will be available on the UNSW Bookshop website from 1 July.

Recommended

Refer to Course Profile supplied.

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© The University of New South Wales (CRICOS Provider No.: 00098G), 2004-2011. The information contained in this Handbook is indicative only. While every effort is made to keep this information up-to-date, the University reserves the right to discontinue or vary arrangements, programs and courses at any time without notice and at its discretion. While the University will try to avoid or minimise any inconvenience, changes may also be made to programs, courses and staff after enrolment. The University may also set limits on the number of students in a course.