Curriculum – AD Transfer Pricing 2018 vr6
Please note that the tutorial questions and the assignments are embedded in the Curriculum Spreadsheet with hyperlinks to make it easier to prepare. But the essential reading materials are set out below, with addition up-to-date reading you should be doing as changes are made by the OECD and other bodies/institutions (see Latest updated reading materials):
Reading materials per lecture – https://iitfconnect.com/?p=1043
Latest updated reading materials:
Prescribed reading:
6 Chapter Transfer Pricing B Arnold International Tax Primer 3rd ed
8 Chapter An introduction to Tax Treaties
An Overview of Transfer Pricing by IBFD
OECD Income and Capital Model Convention and Commentary 2017
OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017
UN TPG 2017 for download – http://192.168.1.1:8181/http://www.un.org/esa/ffd/wp-content/uploads/2017/04/Manual-TP-2017.pdf
TPA Country summaries library: https://www.tpa-global.com/dv/page23901/country-summaries
TP cases to consider:
Tax Risk Management is an important process you must implement for TP clients. Here are the required reading materials, on which you will be examined. This information covers ethical and management issues you must be aware of, which are discussed from time-to-time in the lectures:
The Tax Risk Management pdf copy handbook “Tax Intelligence”:
Here is the summary book:
Here is a tax risk management plan template, based on our one project in Hungary for a MNE:
TRM Policy Document PRECEDENT General with Hungary – case study
This can be used by you in formulating a TRM plan for TP clients.
