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Transfer Pricing: Practice and Problems (LAWS70203)
Graduate coursework level 7Points: 12.5Online
About this subject
- Overview
- Eligibility and requirements
- Assessment
- Dates and times
- Further information
- Timetable (login required)(opens in new window)
Contact information
March
Lecturers
Associate Professor Michael Kobetsky (Coordinator)
Shannon Smit
Email: law-masters@unimelb.edu.au
Phone: 13 MELB (13 6352), International: +(61 3) 9035 5511
Website: law.unimelb.edu.au
Overview
Availability(Quotas apply) | March - Online |
---|---|
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: 31 January 2024
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: 31 January 2024
Assessment
Description | Timing | Percentage |
---|---|---|
Class participation | Throughout the teaching period | 10% |
Take-home examination
| 26 - 29 April 2024 | 90% |
Hurdle requirement: A minimum of 75% attendance is required. | Throughout the teaching period | N/A |
Last updated: 31 January 2024
Quotas apply to this subject
Dates & times
- March - Online
Principal coordinator Michael Kobetsky Coordinator Shannon Smit Mode of delivery Online Contact hours Total time commitment 150 hours Pre teaching start date 21 February 2024 Pre teaching requirements Please refer to the Reading Guide on the LMS subject page for confirmation of which resources need to be read and what other preparation is required before the teaching period commences. Teaching period 20 March 2024 to 26 March 2024 Last self-enrol date 26 February 2024 Census date 21 March 2024 Last date to withdraw without fail 5 April 2024 Assessment period ends 29 April 2024 March contact information
Lecturers
Associate Professor Michael Kobetsky (Coordinator)
Shannon SmitEmail: law-masters@unimelb.edu.au
Phone: 13 MELB (13 6352), International: +(61 3) 9035 5511
Website: law.unimelb.edu.au
What do these dates mean
Visit this webpage to find out about these key dates, including how they impact on:
- Your tuition fees, academic transcript and statements.
- And for Commonwealth Supported students, your:
- Student Learning Entitlement. This applies to all students enrolled in a Commonwealth Supported Place (CSP).
Subjects withdrawn after the census date (including up to the ‘last day to withdraw without fail’) count toward the Student Learning Entitlement.
Additional delivery details
This subject has a quota of 30 students.
Enrolment is on a 'first in' basis. Waitlists are maintained for subjects that are fully subscribed.
Students should note priority of waitlisted 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.
Melbourne Law School may reserve places in a subject for incoming international cohorts or where a subject is core to a specialisation with limited alternate options.
Last updated: 31 January 2024
Further information
- Texts
Prescribed texts
Specialist materials will be made available via the LMS in the pre-teaching period.
- Related Handbook entries
This subject contributes to the following:
Type Name Course Master of Commercial Law Course Graduate Diploma in International Tax Course Master of Laws Course Master of Public and International Law Course Graduate Diploma in Tax Course Graduate Diploma in International Law Course Master of Tax Course Master of International Tax - 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-masters@unimelb.edu.au for subject coordinator approval.
- Available to Study Abroad and/or Study Exchange Students
This subject is available to students studying at the University from eligible overseas institutions on exchange and study abroad. Students are required to satisfy any listed requirements, such as pre- and co-requisites, for enrolment in the subject.
Last updated: 31 January 2024