Applying Transfer Pricing

Singapore University of Social Sciences

Applying Transfer Pricing (TAX531)

Synopsis

TAX531 Applying Transfer Pricing builds on TAX525 Transfer Pricing, which provided the student with the opportunity to explore the challenges of the OECD Transfer Pricing Guidelines for Multinational and Tax Administrators. A Transfer Pricing Report is the usually the basis upon which a multinational’s transfer pricing policy is defended, and is also the main document submitted to the tax authority for their scrutiny. The Report is therefore a vital piece of documentation that can either be prepared from as a compliance requirement, an aggressive planning tool, or as a defensive document. In any case, understanding of the application of the rules covered in TAX525 is key to this course, as students are taken through the application of the principles through case studies and exercises. At the end of this course, students will have the skills to prepare a transfer pricing report complying with OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and will also be able to critique a report, evaluating whether or not a report is acceptable under those guidelines.

Level: 5
Credit Units: 5
Presentation Pattern: EVERY JAN

Topics

Review of the Core Principles of Transfer Pricing
Evidence for Tax Purposes
Transfer Pricing Documentation
The Content of the Transfer Pricing Report

Learning Outcome

Evaluate OECD and Singapore Transfer Pricing Guidelines
Construct arguments using the transfer pricing principles covered
Apply the transfer pricing principles to realistic fact situation(s), computing where required an arm’s length range
Critique and defend position(s) taken in transfer pricing applying the arm’s length principle
Prepare an outline transfer pricing report, fact pattern or case analysis, identifying gaps and write-up that would need to be filled to complete the report
Assess relevant legislation, tax authority guidance and cases identifying short-comings, and suggesting possible improvements
Assemble paper or web resources to conduct research
Examine and analyse legal materials which are written in technical or complex language
Compose and present data provided in numerical or statistical form
Discuss through different forms of communication, such as verbal, written and formal presentations, presenting knowledge or an argument in a way which is comprehensible to others