CloseHelpPrint
Kies de Nederlandse taal
Course module: 695042-M-6
695042-M-6
Transfer Pricing
Course info
Course module695042-M-6
Credits (ECTS)6
CategoryMA (Master)
Course typeCourse
Language of instructionEnglish
Offered byTilburg University; Tilburg School of Economics and Management; TiSEM: Tax Economics; Tax Economics;
Is part of
M Research Master in Business
M Tax Law
M Tax Economics
M International Business Taxation: Economics
M International Business Taxation: Law
Lecturer(s)
Lecturer
R. Garcia Anton
Other course modules lecturer
Lecturer
dr. C.A.T. Peters
Other course modules lecturer
Academic year2020
Starting block
BLOK 1
Course mode
Full-time
RemarksCaution: this information is subject to change
Registration openfrom 25/08/2020 up to and including 20/08/2021
Aims
Objectives of the course:
  • The student has knowledge of the legal and economic backgrounds of the arm’s length principle and he/she is able to evaluate the advantages and disadvantages of this principle with the help of the provided literature. This means that he/she is also able to place this principle in the context of developments in society in the field of tax planning and that he/she can offer an alternative to the principle that takes account of these developments.
  • The student has insight into the organization of a multinational company and into the relevant changes in these organizations (i.e. the development of global value chains and the centralization of functions). A central element of this knowledge concerns the insight into the most important business models of a multinational company. The student must be able to evaluate the development of these organizations with the help of the provided literature.
  • The student has an in-depth knowledge of the relevant law that gives substance to the arm’s length principle and he/she is able to apply this knowledge to practical cases derived from practice. These case studies not only include the ‘standard’ situations in the main business models, but also specific capita selecta (i.e. intangibles and cost distribution agreements and cross-border business restructurings).
  • The student has knowledge of some formal-legal aspects of transfer pricing.
  • The student has detailed knowledge of the importance of transfer pricing for the management control of a multinational company and of the influence of the new international standards (such as country-by-country reporting) on this control. With this knowledge, the student is able to analyse and evaluate the interaction between management control and tax obligations.
  • The student can independently conduct a scientifically based research in the field of transfer pricing.
  • The student can report clearly and concisely in writing about the research.
  • The student can give an insightful presentation about the research and debate it.
Content
These objectives of the course are elaborated in the following topics as they will be discussed in the eight lectures.
 
1. Transfer pricing: an introduction
  • Defining the problem and looking ahead to the different lectures.
  • The arm’s length principle: basic principle, relevant sources of law, definition of affiliated bodies, international discussion on the principle (BEPS, state aid procedures).
2. Application of the arm’s length principle
  • The basic elements of the arm’s length principle: i.e. comparability analysis and functional analysis.
  • The transfer pricing methods: Comparable Uncontrolled Price method (CUP), Resale price method, Cost plus method, Transactional net margin method (TNMM), Profit split method.
3. Application of the arm’s length principle (continuation of lecture 2)
  • The transfer pricing methods: Comparable Uncontrolled Price method (CUP), Resale price method, Cost plus method, Transactional net margin method (TNMM), Profit split method.
  • Application of the transfer pricing methods in ‘standard situations’
4. Critical discussion of the arm’s length principle and introduction to some formal-legal aspects of transfer pricing
  • Critical comparison of the arm’s length principle with alternative methods
  • Documentation requirements (including developments in country-by-country reporting)
  • Safe harbours
 5. ‘Inside a multinational company’
  • The organization of a multinational company
  • Global value chains
  • Business models
  • The centralization of functions: the spectrum from a complete local structure to a principal structure
 6. Application of the arm’s length principle: some capita selecta
  • Intangibles and cost contribution agreements (CCA’s)
  • Cross-border business restructuring
 7. Some formal-legal aspects of transfer pricing
  • Advance Pricing Agreements
  • Transfer pricing corrections
  • Disputes about transfer pricing
 8. Tax governance of a multinational company
  • Transfer pricing and management control
  • The implementation of country-by-country reporting
Course available for exchange students
Master level, conditions apply
Contact person
dr. C.A.T. Peters
Timetable information
Transfer Pricing
Required materials
Literature
-
ISBN:9789041159854
Title:Introduction to Transfer Pricing (latest edition)
Author:Jérôme Monsenego
Publisher:Kluwer Law International
Reader
The syllabus for the course is available in Canvas. In the syllabus you will find the course materials that should be studied for every lecture. The relevant scientific articles can be downloaded in the databases of the library.
Recommended materials
-
Tests
Three Weekly Assignments (25%)

Final grade

Grade paper and oral defense (75%)

CloseHelpPrint
Kies de Nederlandse taal