Brief Introduction
PE's, Compliance and Dispute ResolutionDescription
Course Aims
The aim of this module is to ensure a student understands how certain of the more complex type of TP transactions are to be identified, treated, analysed and priced in terms of the OECD guidelines, specifically for business restructuring and permanent establishments.
The module aims to provide guidance to a student on what classifies as a business restructuring and how the arm’s length principle is to be applied in such circumstances.
For permanent establishments, the module aims to provide the student with guidance on the arm’s length principle. Articles 5 and 7 of the OECD Model Tax Convention, and the attribution of profits principles are to be explained in detail.
The module explains the documentation requirements per the OECD guidelines and specific points relating to the BEPS Action list. The concept of risk management is explained to the student. Key management implications relating to risk management is discussed with the student.
The concept of dispute resolution is explained to the student, specifically the procedures of MAP’s, APA’s and corresponding adjustments.
As in module 1, the student is also provided with guidance relating to Ethics within the documentation, risk management and dispute resolution themes.
On successful completion of this module, the student should be able to:
1. Identify and evaluate transfer pricing aspects of business restructurings.
2. Justify the applicability of the arm’s length principle for business restructuring transactions.
3. Interpret tax treaty definitions of what constitutes a permanent establishment as set out in the OECD Model Tax Convention.
4. Outline the risk management principles per the documentation requirements of the OECD guidelines.
5. Present the dispute resolution mechanisms used to resolve disputes within enterprises (such as the Mutual Agreement Procedure and the Advance Transfer Pricing Agreement).
Consider the ethical and moral issues raised by present-day transfer pricing practices.
Requirements
- Requirements
- Knowledge of International Taxation principles
- Basic understanding of Transfer Pricing
Quebiko Training
4 Raiting
Logistics of crude oil and petroleum products - Oil and gas
- 4.3
-
![]()
![]()
![]()
![]()
![]()
Explore the logistics of crude oil and petroleum products - transport and dispatch of oil and gas demystified Dear student, The course is organized into 2 parts :...
RA: Data Science and Supply chain analytics.(A-Z with R)
- 4.6
-
![]()
![]()
![]()
![]()
![]()
Learn R,Supply-chain Data Science, Inventory Optimization,Big Data forecasting, Machine learning and Revenue Management. "Learning Data science is boring! learning data science for a purpose is fun!!"...
Business & Marketing Strategy for Real Estate Photographers
- 4.9
-
![]()
![]()
![]()
![]()
![]()
How to develop a business strategy and marketing plan for your real estate photography business. Business & Marketing Strategy for Real Estate Photographers...
FRM Part 1 (2020) - Book 1 - Foundations of Risk Management
- 4.3
-
![]()
![]()
![]()
![]()
![]()
FRM Course by Prof. James Forjan In this course, Prof. James Forjan has taught college-level business classes for over 25 years....
