This course will provide participants with an in-depth coverage of the critical areas of transfer pricing currently subject of developments in the international tax arena and discussion amongst scholars and the tax community. Particular focus will be dedicated to aspects of transfer pricing such as advance pricing agreements (APAs), increasingly considered a administrative tool for dispute prevention, the interaction between accountancy and transfer pricing models, the importance of filing a documentation package in order to avoid penalties and the increasing use of cost sharing agreements (CSAs) to optimize returns on intangibles. A number of examples will be used throughout the course.

Topics covered in this course include:

• Administrative Cooperation for Better Dispute Prevention: Advance Pricing Agreements (APAs) a feasible legal tool?
• Resolution under the Mutual Agreement Procedure (MAP) and arbitration
• Global Documentation Strategies and Transfer Pricing Penalties
• The Role of Transfer Pricing in Preparing Financial Statements
• Transfer Pricing Implication of Intra-Group Services
• Intangibles and Cost Sharing Agreements