The 20th century was the age of globalization, which highly influenced business and taxation. While the multinational enterprises (MNEs) took advantage of new possibilities and established their activities all around the world, international policymakers and local authorities faced the challenge of adapting the regulations to the new reality to prevent increasing abuses.

Transfer pricing (TP) is at the forefront of these changes. It is a tool ensuring that MNEs are taxed fairly and under market conditions in each country where they operate. Such rules are needed since 80% of

transactions in global trade are performed within MNEs. Even though TP has its roots in tax law, it connects legal and economic aspects of business. With the fast-paced globalization, TP has recently gained more significance than ever. Many high-profile cases of tech giants such as Google, Apple, Facebook or Amazon prove the central role of TP in tax schemes. The ongoing international discussion on the taxation of new digital business models will ensure that TP remains one of the most topical and debated branches of international tax law.

With the above in mind, this course aims to familiarize you with the meaning of TP and its basic concepts during four following classes:

• What is this all about? The fundamentals of TP.

Our course starts with the fundamental questions, such as what is TP and why do we need it. We will discuss its historical background and contemporary approaches. International developments and the legal basis for TP in domestic law systems will also be addressed.

• TP for specific transactions: Services, Financing and Intangibles

The most relevant type of transactions from a TP perspective are exchange of intra-group services, provisions of financial activities, and licensing/transfer of intangibles. Therefore, the remaining three classes will be dedicated to each of these topics.  

After the course, you will be familiar with the concept of transfer pricing as well as its practical application to the most relevant intra-group transactions.

> 70% attendance requirement

Every unit of the course will consist of two parts – a lecture on the specific topic of the class and case studies to show the practical impact of the issues discussed. The case study solved by the students during each class, under the guidance of the lecturers.

Participation: 20%

Exam: 80%