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Transfer Pricing: Practice and Problems (LAWS70203)
Graduate coursework level 7Points: 12.5On Campus (Parkville)
About this subject
- Overview
- Eligibility and requirements
- Assessment
- Dates and times
- Further information
- Timetable(opens in new window)
Contact information
September
Lecturers
Associate Professor Michael Kobetsky, Coordinator
Ms Shannon Smit
Email: law-masters@unimelb.edu.au
Phone: +61 3 8344 6190
Website: law.unimelb.edu.au
Overview
Availability(Quotas apply) | September |
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Fees | Look up fees |
International transfer pricing is the price charged for the cross-border transfer of assets or services between associated enterprises in a multinational enterprise group. Transfer pricing is consistently identified in international surveys of multinational enterprises as the most important tax issue they face. Multinational enterprises have to deal with demands from the various jurisdictions in which they operate as national tax agencies implement measures to protect their revenue from cross-border trade between associated entities.
This subject studies the Australian transfer pricing rules and their application. The Australian transfer pricing rules are based on the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines. This subject is designed for tax advisers, in-house tax managers and government officials, as well as those practising in transfer pricing. A background in transfer pricing is not required.
Principal topics include:
- OECD guidelines on transfer pricing
- Australia’s tax legislation and tax rulings on transfer pricing
- Australia’s tax treaties and transfer pricing
- Case law
- Transfer pricing methodologies—selection and application for the following transactions in respect of tangible goods, intangible assets, services and financial transactions
- Transfer pricing documentation requirements
- Performing a comparable search (benchmarking)
- Completing the transfer pricing section of the tax return
- Risk reviews and audit approach.
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an integrated understanding of aspects of Australian transfer pricing rules, case law and aspects of the OECD Transfer Pricing Guidelines
- Be able to critically examine, analyse, interpret and assess the effectiveness of the transfer pricing rules and principles
- Be an engaged participant in the debate on the controversial issues in transfer pricing
- Have an understanding of the challenges in applying the underlying arm’s length principle to intra-group cross-border transactions
- Have the cognitive and technical skills to critically evaluate the transfer pricing principles
- Have the communicative skills to articulate and express complex information on transfer pricing to specialist and non-specialist audiences
- Be able to demonstrate judgment and responsibility in the field of transfer pricing.
Last updated: 3 November 2022
Eligibility and requirements
Prerequisites
None
Corequisites
None
Non-allowed subjects
None
Recommended background knowledge
Applicants without legal qualifications should note that subjects are offered in the discipline of law at an advanced graduate level. While every effort will be made to meet the needs of students trained in other fields, concessions will not be made in the general level of instruction or assessment. Most subjects assume the knowledge usually acquired in a degree in law (LLB, JD or equivalent). Applicants should note that admission to some subjects in the Melbourne Law Masters will be dependent upon the individual applicant’s educational background and professional experience.
Inherent requirements (core participation requirements)
The University of Melbourne is committed to providing students with reasonable adjustments to assessment and participation under the Disability Standards for Education (2005), and the Assessment and Results Policy (MPF1326). Students are expected to meet the core participation requirements for their course. These can be viewed under Entry and Participation Requirements for the course outlines in the Handbook.
Further details on how to seek academic adjustments can be found on the Student Equity and Disability Support website: http://services.unimelb.edu.au/student-equity/home
Last updated: 3 November 2022
Assessment
Additional details
- Class participation (10%)
- Take-home examination (5,000 - 6,000 words) (90%) (19 - 22 October)
A minimum of 75% attendance is a hurdle requirement.
Last updated: 3 November 2022
Quotas apply to this subject
Dates & times
- September
Principal coordinator Michael Kobetsky Mode of delivery On Campus (Parkville) Contact hours 24-34 hours Total time commitment 150 hours Pre teaching start date 15 August 2018 Pre teaching requirements The pre-teaching period commences four weeks before the subject commencement date. From this time, students are expected to access and review the Reading Guide that will be available from the LMS subject page and the subject materials provided by the subject coordinator, which will be available from Melbourne Law School. Refer to the Reading Guide for confirmation of which resources need to be read and what other preparation is required before the teaching period commences. Teaching period 12 September 2018 to 18 September 2018 Last self-enrol date 8 December 2017 Census date 12 September 2018 Last date to withdraw without fail 5 October 2018 Assessment period ends 22 October 2018 September contact information
Lecturers
Associate Professor Michael Kobetsky, Coordinator
Ms Shannon SmitEmail: law-masters@unimelb.edu.au
Phone: +61 3 8344 6190
Website: law.unimelb.edu.au
Additional delivery details
This subject has a quota of 30 students.
Enrolment is on a first come, first served basis. Waitlists are maintained for subjects that are fully subscribed.
Students should note priority of places in subjects will be given as follows:
- To currently enrolled Graduate Diploma and Masters students with a satisfactory record in their degree
- To other students enrolling on a single subject basis, eg Community Access Program (CAP) students, cross-institutional study and cross-faculty study.
Please refer to the Melbourne Law Masters website for further information about the management of subject quotas and waitlists.
Last updated: 3 November 2022
Further information
- Texts
Prescribed texts
Specialist printed materials will be made available free of charge from the Melbourne Law School prior to the pre-teaching period.
- Related Handbook entries
This subject contributes to the following:
Type Name Course Graduate Diploma in Legal Studies Course Graduate Diploma in International Law Course Graduate Diploma in International Tax Course Graduate Diploma in Tax Course Master of Commercial Law Course Master of International Tax Course Master of Laws Course Master of Tax Course Master of Public and International Law - Links to additional information
- Available through the Community Access Program
About the Community Access Program (CAP)
This subject is available through the Community Access Program (also called Single Subject Studies) which allows you to enrol in single subjects offered by the University of Melbourne, without the commitment required to complete a whole degree.
Entry requirements including prerequisites may apply. Please refer to the CAP applications page for further information.
Additional information for this subject
If required, please contact law-admissions@unimelb.edu.au for subject coordinator approval.
Last updated: 3 November 2022