LAWS6123 - Transfer Pricing in International Taxation

Objectives

Undertake an examination of transfer pricing law and practice in Australia in the area of international taxation.
Examine the topic in the context of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, the rewrite of the US Regulations and the substantial transfer pricing rulings program of the Australian Taxation Office.
Gain an understanding of the policy and detailed application of transfer pricing rules within Australia as well as an understanding of the international framework.

Content

Legal framework for Australia’s transfer pricing (including tax treaties); transfer pricing methodologies applicable to supplies of goods, services, and intangibles; documentation; transfer pricing dispute resolution; corporate restructures; transfer pricing and branches; and recent OECD developments.

Session

Semester 2 Intensive
15-17 & 20-21 September 2010

The timetable is subject to frequent changes. Please refer to the latest version of the Postgraduate Timetable.

Assessment

1 x 3,000 Word Assignment (30%)
1 x Two-Hour Exam (70%)

Assumed Knowledge

It is recommended that candidates who are not working in the tax area and have not taken an undergraduate tax unit in Australia in the past five years undertake LAWS 6128 - Comparative International Taxation or LAWS 6209 - Australian International Taxation before enrolling in this unit. If in doubt,
please consult the Taxation Program Coordinator.

Courses this unit is available in

Sydney Law School