Transfer Pricing
Overview:
From this class you will become aware that Transfer Pricing. which is define-d differently depending on the standards adopte-d by each country. Even in the US transfer pricing best practices differ. Each of you are require-d to write a paper in the area of Transfer Pricing for this class. However, Following the overall format of the class, you are responsible for identifying an area. Which you wish to research and proposing a hypothesis statement – the point you would like to prove/disprove. That is, you have the freedom to write on any transfer pricing topic you want.
The only constraint is that we discuss the topic and I approve the hypothesis statement. Ultimately, I am here to help you in picking a workable topic and reserve the right of final approval on topics. Therefore, the constraints of the paper are as follows: It must relate to Transfer Pricing. You provide an Hypothesis statement on what you will prove (I recommend discussing the Hypothesis statement with me.) If applicable, describe the transaction or class of transactions. Your paper includes references and tax nomenclature.
Summary:
Arm’s Length Standard – The Arm’s Length Standard has been developed by the U.S. and OECD in IRC 482 and the OECD Guidelines over the last four decades. While there are some variations in the approach, the two standards are generally considered to approximate each other. Potential papers about the arm’s length standard include:
The Paper is to write how The Arm’s Length Standard and BEPS 2.0 compares – where does the Arm’s Length Standard go from here.
Do not just copy and paste – write in your own words and explain “where you think the arm’s length transaction goes from here” and defend your hypothesis/answer with your own rationale examples and support your argument logically.
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