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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: 17 March 2021