5385 Introduction to Transfer Pricing
Raffaele Petruzzi, Ph.D., Ruth Mirembe, LL.M., Marcelo Henrique Barbosa Moura, LL.M., Abhishek Padwalkar, LL.M.
Weekly hours
Language of instruction
02/21/23 to 03/01/23
Registration via LPIS
Notes to the course
Day Date Time Room
Wednesday 03/15/23 09:00 AM - 12:30 PM TC.3.09
Wednesday 03/22/23 09:00 AM - 12:30 PM TC.3.09
Wednesday 03/29/23 09:00 AM - 12:30 PM TC.3.09
Wednesday 04/12/23 09:00 AM - 12:30 PM TC.3.09
Wednesday 04/19/23 09:00 AM - 12:30 PM TC.3.09
Wednesday 04/26/23 09:00 AM - 12:30 PM TC.3.09
Wednesday 05/17/23 09:00 AM - 12:30 PM TC.3.09
Wednesday 05/31/23 08:30 AM - 12:00 PM TC.5.03

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 companies such as Google, Apple, Facebook or Amazon prove the central role of transfer pricing 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 the students with the meaning of TP and its basic concepts during twelve classes (in six days - see the first six dates) covering the following topics:

· background and historical evolution of TP;

· the arm’s length principle;

· application of the arm’s length principle;

· TP methods;

· TP adjustments;

· TP documentation;

· methods to avoid/minimize TP disputes;

· TP dispute resolution;

· permanent establishments and profit attribution.

Learning outcomes

After the course, students will be familiar with the concept of transfer pricing as well as the modes of its application in practice, common problems and solutions. Upon completion of the course, students will have the knowledge of the following issues:

· legal basis for the application of TP rules and non-binding sources of the interpretation and application of these rules;

· the idea of the arm’s length principle and correct application of the arm’s length principle;

· performing a functional analysis of the business processes in a big multinational company;

· TP methods and their application;

· TP adjustments;

· TP documentation in multinational enterprises;

· cooperation between multinational enterprises and tax authorities; ways to avoid disputes and dispute resolution;

· permanent establishments and the attribution of profits.

Attendance requirements

Students have to be present during at least 10 out of 12 classes (which will be taught in six days, see the first six dates) in order to be allowed to take the final exam.


Teaching/learning method(s)

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 first case study will be discussed by the lecturers with the entire class, whereas the second case study will have to be solved entirely by the students during each class, divided into groups of 4-5 persons and afterwards presented in front of the other participants.


Students will be assessed on the basis of two components: activity in class (20% of the final grade) and the final exam (80% of the final grade). Points for the activity in class will be assigned after every unit, taking into account students’ participation in solving case studies. Activity points will be included in determining the final grade only if the student passes the final exam.

Prerequisites for participation and waiting lists

For students of Wirtschaftsrecht: During the registration period places are allocated according to the "first-come, first-served" principle. After the registration period, students from the waiting list who don't yet have a valid registration will be assigned to available places based on their progress in their studies. Preference will be given to students who have successfully completed the “basic course” (Grundkurs Steuerrecht) and the advanced course ( "Vertiefungskurs Steuerrecht") in Tax Law.


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Last edited: 2023-03-02