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 increasingly 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 and Amazon prove the central role of TP in tax schemes. The ongoing international discussion on the taxation of new digital business models confirm that TP remains one of the most topical and debated branches of international tax law.

With the above in mind, this course aims to make you familiar with the meaning of TP and its fundamental concepts during the following classes:

• What is this all about? An introduction to TP.

Our course starts with the fundamental questions, such as what is TP and why 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. Finally, it will be explained how to perform a proper TP analysis.

• TP for specific transactions

The most relevant type of transactions from a TP perspective are exchange of intra-group services, provisions of financial activities, licensing/transfer of intangibles, business restructurings, and attribution of profits to permanent establishments. Therefore, specific classes will be dedicated to each of these topics.  

• A look into the future: TP and the digitalization of the economy

The increasing digitalization of the economy has brought forward numerous challenges for the current transfer pricing rules. Therefore, the OECD, the United Nations as well as other relevant international organizations, together with governments from all over the world, are working on how to address those challenges. The last class will be dedicated to explain the current updates on these topics, looking to how transfer pricing will evolve in the future.

After the course, you will be familiar with the fundamental concepts related to TP 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 a case study to show the practical impact of the issues discussed. The case study will be solved by the students during each class, under the guidance of the lecturer.

Participation: 20%

Exam: 80%

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• 1. When writing a seminar paper, the introduction must contain a declaration of the use of AI. If no form of AI was used, a note to this effect is sufficient. If AI was used, the introduction must explain accordingly where and in what form.
  2. For seminar papers, increased attention will be paid to:
• Whether the processed legal status is up-to-date
• Correct/existent citations
• Correct use of abbreviations
• Comprehension
• Errors in the outline