The Seminar deals with the following topics:

• OECD Transfer Pricing Guidelines 2017
• Basic issues for Transfer Pricing post-BEPS: Arm`s-Length Principle, Functional and Value Chain Analysis, OECD Transfer Pricing methods, Comparability issues, Transfer Pricing documentation and ways to avoid/minimize double taxation from Transfer Pricing (APAs, MAPs, Arbitration)
• Post-BEPS Permanent Establishments (BEPS Action 7) and Profit Attribution with Case Studies
• Transfer Pricing and Group Financing with Case Studies 
• Transfer Pricing and Intangibles - License model (BEPS Action 8) with Case Studies

After the lecture the participants will have knowledge about key topics in the area of Transfer Pricing in international companies (MNEs) and the OECD Transfer Pricing Guidelines 2017  

Furthermore, participants will be able to:

• analyse international tax law questions in respect of Transfer Pricing on the basis of the new OECD Guidance (domestic tax laws versus international “soft law”),
• analyse and evaluate comprehensive, international facts/cases concerning Transfer Pricing.

> 70% attendance requirement

Lecture with case studies / court cases and discussions

The Seminar requires basic knowledge about:

• company taxation in an international context,
• the OECD Model Tax Convention as well as the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and
• the Austrian international tax law, including the Transfer Pricing rules (VPR).

Prof. Dr. Alfred Storck

alfred.storck@wu.ac.at

T +43-1-313-36-5930

M +41 79 766 3997