- Explain and classify the basic principles of transfer pricing and their significance for companies (k2).
- Interpret OECD transfer pricing guidelines and relevant national regulations and apply them to specific situations (k2, k3).
- Select methods for determining appropriate transfer prices and apply them using case studies (k3, k4).
- Carry out functional and risk analyses using example companies and assess their impact on transfer pricing (k3, k4).
- Know and reproduce documentation requirements for transfer prices in accordance with international guidelines and national regulations (k2).
- Identify tax risks from transfer pricing adjustments and assess their impact on the tax base (k4, k5).
- Analyze mechanisms for avoiding and resolving disputes (e.g. Advance Pricing Agreements (APA), Mutual Agreement Procedure (MAP)) and apply them to case studies (k4, k5).
- Independently analyze and solve case studies on transfer pricing issues (k4, k5).
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- Legal bases of transfer pricing at national, European and OECD level.
- Relevant methods of transfer pricing (e.g. Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus, Transactional Net Margin Method (TNMM), Profit Split).
- Transfer pricing documentation requirements and their enforcement by tax authorities.
- Effects of transfer pricing adjustments on the tax base, profit allocation and tax burden of multinational companies.
- Strategies for avoiding and resolving transfer pricing conflicts with tax authorities.
- Current developments in international transfer pricing policy, in particular with regard to OECD-BEPS measures and EU requirements.
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