Advanced Diploma – Transfer Pricing Curriculum and reading materials

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://www.africataxjournal.com/?p=1043

Latest updated reading materials:

The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10

Prescribed reading:

A Practical Summary of the 2017 OECD TPG –  https://www.dropbox.com/s/ynsl1x2h3sk037e/A%20practical%20summary%20of%20the%20July%202017%20OECD%20-%20Johann%20H.pdf?dl=0

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

PWC International TP 2015-16

TPA Country summaries library: https://www.tpa-global.com/dv/page23901/country-summaries

TP cases to consider:

TP cases related to TP online course

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”:

http://taxriskmanagement.com/wp-content/uploads/2018/03/a-Tax-Intelligence-The-7-Habitual-Tax-Mistakes-Made-by-Companies-updated-26-Jan-2018.pdf

Here is the summary book:

http://taxriskmanagement.com/wp-content/uploads/2018/03/7-Habitual-Tax-Mistakes-updated-26-Jan-2018.pdf

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.