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2018 Principles of International Transfer Pricing
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2018/04/04 to 2018/04/06
When: 4 April 2018
From 9:00am until 5:00pm
Where: Colosseum Luxury Hotel
Cnr Century Way & Century Boulevard
Century City
Cape Town, Western Cape  7441
South Africa
Contact: Thabelo Raivhogo

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I Fundamental sources

  1. Tax treaties (OECD and UN Model Conventions)
  2. OECD Transfer Pricing Guidelines (TPG)
  3. OECD BEPS 2015 Final Reports (Actions 8-10)
  4. UN Practical Manual on Transfer Pricing
  5. Transfer pricing litigation cases (see list)
  6. EU-JTPF Codes of Conduct guidelines and reports

VII Permanent Establishments (PEs)

  1. Article 5 Permanent Establishments (OECD & UN)
  2. Article 7 Business Profits (OECD and UN)
  3. Understanding the importance of PEs

II The Arm’s Length Principle (ALP)

  1. Interpretation of the arm’s length principle
  2. Associated enterprises
  3. Global Formulary Apportionment
  4. Recognition of the actual transactions undertaken
  5. Losses and the effect of government policy

VIII Compliance issues

  1. Documentation
    1. OECD BEPS 2015 Final Reports (Action 13)
    2. Country by country reporting, master and local file
  2. Examination practices, burden of proof and penalties
  3. Risk assessment and risk management
  4. Audits

III Functional analysis

  1. Goal of functional analysis
  2. Analysis of functions, assets and risks (FAR)
  3. Relating functional analysis to TP method chosen
  4. Entity characterisation (e.g. entrepreneur”, etc.)
  5. Practical approach to functional analysis

IX Avoiding Double Taxation and dispute resolution

  1. Adjustments
  2. Mutual agreement procedure (BEPS Action 14)
  3. Arbitration Article 25(5)
  4. EU Arbitration Convention
  5. Advance Pricing Agreements

IV Transfer pricing methods

  1. Description of methods
  2. Selection and application of the method(s)

X Other issues

  1. Base Erosion and Profit Shifting Project
  2. Interaction between Customs Valuation and TP
  3. Safe Harbours and Tax Incentives
  4. E-commerce and transfer pricing
  5. Worldwide recent developments in transfer pricing

V Comparability methods

  1. Significance of comparability
  2. Performing a comparability analysis
  3. Dealing with the lack of comparable data
  4. Sources of comparables
  5. Timing and compliance issues in comparability


  • Chevron Australia v Comm of Tax [2017 FCAFC 62]
  • DSG [2009 UKFTT 31 (TC)]
  • GE Capital [2010 FCA 344]
  • GSK Canada [2010 FCA 201]
  • Ireland/Apple state aid [SA.38373]
  • LGElectronics ID v ACIT [2013 29 300]
  • Roche Products Property [2008 AATA 261]
  • Netherlands/Starbucks state aid [SA.38374]
  • SNF (Australia) v Comm of Tax [2010 FCA 635]

VI Specific transactions

  1. Intra-group services
  2. Intra-group financial transactions
  3. Intangible property
  4. Business restructurings
  5. Cost Contribution Arrangements/Agreements

Course Content

  • Three intensive days of 7-hours of:
    • Lectures;
    • case studies (including ADIT exam questions); and
    • the opportunity to ask all the questions you would like.
  • Johann Muller’s “Summary of the 2017 OECD Transfer Pricing Guidelines”, selling on Amazon for USD 35 ex VAT.
  • UN Practical Manual; EU Directives; case law in soft copy.
  • Preparation for the Transfer Pricing exam of the UK Chartered Institute of Taxation’s Advanced Diploma in International Taxation (should one be interested in doing that).


Johann Müler

Johann has been working in tax since 1990. First as a consultant in Amsterdam, London, New York and Copenhagen. I have been deputy head of tax of a global 150 group and a case handler for the Danish competent authority; I also represented them at WP6 at the OECD.


This event will secure 21 hours verifiable output CPD points/units. Including the following professional bodies: SAICA, CIMA, SAIPA, SAIBA, ACCA, FPI, CSSA, LSSA, FISA, ICBA, IAC, AAT

Event Investment

This event does not form part of the CPD subscription package.


Member & Non-member: R13680.00

Click here to register for the seminar

Event time: 09.00 – 17.00

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