Transfer Pricing

Catalog description

Credits 2. 2 Lecture Hours. Addresses cross-border intracompany pricing as a multidisciplinary subject of law, accounting and economics in order to value cross-border tangibles, services and intangible transactions among units of a multinational enterprise; examination from a U.S. law perspective compared to OECD, UN and other country approaches, especially Brazil; includes arm's length standard, jurisprudence, comparability analysis, risk analysis for tangibles and intangibles, transactional methods (CUP, CUT, Cost Plus, Resale Minus, Commodity), profit methods, functional analysis, industry economic data gathering and analysis, cost-sharing arrangements, profit splits and residuals, platform contributions, safe harbors, documentation, advance pricing agreement procedures and mutual agreement procedures. Prerequisites: One year of law school in the full-time or part-time program.