Follow curriculum – Reading:
OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017
Chapter 1: Section D.1.2.2
| BEPS Action 9: Transfer pricing and risks/capital |
| from Actions 8-10 Final Report |
| Intangibles, Risks & Capital, High-Risk Transactions |
| http://www.oecd.org/ctp/beps-actions.htm |
Location savings – BNA Article 1 Location Specific Advantages Sebastien Gonnet
General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of Transfer Pricing by IBFD
Start your Assignment 3 preparation now – start reading the EXTENSIVE DOCUMENTS: thepre-trial filing of Coca-cola to the US tax court, and the long list of supporting articles, and start summarizing the case using the principles in 1 Reading cases SSRN-id1160925 This may appear as a key exam question as well.
The coca-cola case pre-trial document and articles can be found here: https://iitfconnect.com/?p=675
