Transfer Pricing: Arm’s length principle and its application



Concepts and guidance under the OECD’s Transfer Pricing Guidelines

0.0 ★ | (0 ratings) | 4 students | Author:Shehzad Zuberi

Course Duration:

7 sections • 15 lectures • 3h 8m total length


Transfer pricing is one of the most interesting areas in international taxation. Tax professionals, economists, lawyers, and finance professionals enjoy its application as it allows them to study the global business and legal structure of multinational enterprises.This course is on the “arm’s length principle” and its application.  After this course, it will be easier for you to understand the relevant chapters of the OECD’s TP Guidelines. Reading the guidelines will make you familiar with its language, and once you are comfortable with it, you will start enjoying reading the relevant case laws and literature on transfer pricing. After understanding the core concepts of the “arm’s length principle” thoroughly, you will enjoy the process of transfer pricing analysis and the application of the arm’s length principle, controversies around it, case laws, development in the rules and regulations globally, debates and opinions, etc. Course outline:I have provided an overview of the course in the first couple of videos. It will help in tracking your progress and having an overall sense of direction. It starts with the basic statement on the arm’s length principle (ALP) provided in article 9 of the Model Tax Convention issued by the OECD. It then covers the OECD’s guidance contained in its “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations” on the application of the ALP, using the suggested nine-step process of comparability analysis, documentation, and dispute resolution.Big picture – an overview of the arm’s length principle and comparability analysisSimple Example to provide a basic background for the courseArm’s Length Principle – Article 9 of the OECD’s Model Tax ConventionGuidance on the application of the arm’s length principleIdentification of the commercial and financial conditions of the controlled and uncontrolled transactionsThe contractual terms of the transactionsFunctional AnalysisAnalysis of risks in commercial and financial conditionsRisk-free and risk-adjusted rates of returnEconomic circumstanceBusiness strategiesTransfer Pricing MethodsSelection of the most appropriate transfer pricing methodExamples of how TP methods are selected in various intra-group transactions to  Five suggested TP methodsComparability Analysis – The suggested nine-step processTransfer Pricing Documentation Country-by-country reportingMaster FileLocal File


#Understanding of the basic corporate tax and international tax concepts is needed.

What you’ll learn:

#Arm’s Length Principle
#Comparability Analysis
#Transfer Pricing Methods
#Transfer Pricing Documentation
#Dispute Resolution
#OECD Guidelines

Who this course is for:

#Tax professionals and government tax officials#Finance and accounting professionals#Economists intending to have introduction to transfer pricing#Legal professional in international tax practice



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