Singapore University of Social Sciences

Applying Transfer Pricing

Applying Transfer Pricing (TAX531)

Applications Open: 01 October 2020

Applications Close: 30 November 2020

Next Available Intake: January 2021

Course Types: Modular Graduate Course

Language: English

Duration: 6 months

Fees: To be confirmed

Area of Interest: Business Administration, Legal

Schemes: Lifelong Learning Credit (L2C)

Funding: To be confirmed

School/Department: School of Law


TAX531 Applying Transfer Pricing builds on TAX525 Transfer Pricing, which provided the student with the opportunity to explore the challenges of the OECD Transfer Pricing Guidelines for Multinational and Tax Administrators. A Transfer Pricing Report is the usually the basis upon which a multinational’s transfer pricing policy is defended, and is also the main document submitted to the tax authority for their scrutiny. The Report is therefore a vital piece of documentation that can either be prepared from as a compliance requirement, an aggressive planning tool, or as a defensive document. In any case, understanding of the application of the rules covered in TAX525 is key to this course, as students are taken through the application of the principles through case studies and exercises. At the end of this course, students will have the skills to prepare a transfer pricing report complying with OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and will also be able to critique a report, evaluating whether or not a report is acceptable under those guidelines.

Level: 5
Credit Units: 5
Presentation Pattern: Every January


  • Review of the Core Principles of Transfer Pricing
  • Evidence for Tax Purposes
  • Transfer Pricing Documentation
  • The Content of the Transfer Pricing Report

Learning Outcome

  • Evaluate an industry or a function using the Comparability Factors as identified in the OECD Transfer Pricing Guidelines
  • Construct a pool of relevant comparables based on the analysis of comparability factors, and other criteria
  • Compute an arm’s length range
  • Critique, or defend the selection of a transfer price within an arm’s length range
  • Construct an outline transfer pricing report, identifying gaps in data and write-up that would need to be filled to complete the report
  • Critique the transfer pricing process, identifying short-comings, and suggesting possible improvements
  • Assemble paper or web resources to conduct research
  • Examine and analyse legal materials which are written in technical or complex language
  • Compose and present data provided in numerical or statistical form
  • Discuss through different forms of communication, such as verbal, written and formal presentations, presenting knowledge or an argument in a way which is comprehensible to others
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