The MSc in Transfer Pricing will be offered from the second quarter of 2022. The full MSc will provide the candidate with the in-depth knowledge and practical experience in Transfer Pricing that will enable them to fulfil a senior position as a transfer pricing specialist.
The MSc is completed over two full academic years and contains the following 3 Stages:
Stage 1 – Module 1
Students who have already completed this module in the PG-D/ PG-C are not required to complete it again.
- The aim of this module is to highlight the legal framework that covers Transfer Pricing. Transfer Pricing touches multinational corporations, working in multiple jurisdictions. This module will provide the student with an overview of the tools needed to assess the legal environment of a specific jurisdiction when applying the transfer pricing principles. This is a very broad module, however, it lays the foundation for the rest of the course. The appreciation of operating within an ethical framework and specifically within the Transfer Pricing environment is discussed with the students.
- The module also covers the very important Arm’s Length Principle and Functional Analysis, laying the further groundwork for the rest of the course.
- The “Arm’s-Length Principle” of transfer pricing states that the amount charged by one related party to another for a given product must be the same as if the parties were not related. An arm’s-length price for a transaction is therefore what the price of that transaction would be on the open market.
- The functional analysis is used for transfer pricing purposes. It analyzes the functions performed (taking into account assets used and risks assumed) by associated enterprises in a transaction.
Stage1, Module 2
Students who have already completed this module in the PG-D/ PG-C are not required to complete it again.
- The aim of this module is to ensure a student can identify the different TP methods for controlled transactions, identify a comparability analysis and determine an arm’s length charge for Intra-Group Services.
- The student will fully understand how each method works, the specific conditions for a method to be applied and be able to perform the calculations required for each method.
- The module explains the documentation requirements per the OECD guidelines and specific points relating to the BEPS Action list. The concept of risk management is explained to the student. Key management implications relating to risk management is discussed with the student.
- The concept of dispute resolution is explained to the student, specifically the procedures of MAP’s, APA’s and corresponding adjustments.
- As in module 1, the student is also provided with guidance relating to Ethics within the documentation, risk management and dispute resolution themes.
Stage 2, Module 1
Students who have already completed this module in the PG-D are not required to complete it again.
- The aim of this module is to provide the student with a thorough understanding of the comparability analysis, once the transaction has been delineated and the significant comparability factors are taken into account. The comparability analysis is crucial to be able to determine the correction (if any) required to calculate an arm’s length price.
- Intra-group services will be studied, to ascertain when these services are rendered, to determine an arm’s length charge for these services and further conditions relating to the application of the OECD guidelines to intra-group services and low value-adding intra-group services.
- The module further aims to ensure a student understands how certain of the more complex type of TP transactions are to be identified, treated, analysed and priced in terms of the OECD guidelines.
- The module aims to provide sufficient guidance to a student to identify Intangible transactions, their owners, how these are to be priced, how the transfer of intangibles is to be treated & priced and allocations to be made based upon the OECD guidelines and the arm’s length principle.
Stage 2, Module 2
Students who have already completed this module in the PG-D are not required to complete it again.
- The module aims to provide the student with a detailed understanding of cost contribution arrangements, the application of the arm’s length principle to such arrangements and how adjustments are to be made.
- The module aims to provide an understanding of the various types of financial transactions in a TP environment including cash pooling and provides guidance on how to price such transactions on an arm’s length charge.
- The aim of this module is to ensure a student understands how certain of the more complex type of TP transactions are to be identified, treated, analysed and priced in terms of the OECD guidelines, specifically for business restructuring and permanent establishments.
- The module aims to provide guidance to a student on what classifies as a business restructuring and how the arm’s length principle is to be applied in such circumstances.
- For permanent establishments, the module aims to provide the student with guidance on the arm’s length principle. Articles 5 and 7 of the OECD Model Tax Convention and the attribution of profits principles are to be explained in detail.
Stage 3 – Dissertation
- The main objective of the dissertation is to apply your knowledge of Transfer Pricing, through research, to explore the unknown and unlock new possibilities within the practice area of Transfer Pricing.
- The aim of the dissertation is to develop a careful and detailed study of a proposed problem or concern in Transfer Pricing, and implement the knowledge gained from Stages 1 and 2 of the programme in order to sufficiently research, consider and respond to the problem.
- A further aim is an in-depth analysis of the information learned in order to generate new questions, concepts and understandings within the practice area of Transfer Pricing.
Who will benefit from this programme?
The structure of the programme is both theory and practice-oriented, and it is designed in a manner to enrich your advisory and consulting skills. Transfer Pricing is a complex field, and it is essential you get a thorough working knowledge of the OECD and UN Transfer Pricing Guidelines, with the additional reading requirements given to you. The lectures are designed to unpack the complexities of transfer pricing with practical examples enabling you to apply this knowledge to your professional practice.
People who would most benefit from this programme are:
- CFO’s
- Financial Directors
- Financial Managers
- Accountants
- Tax Accountants
- Tax Layers
- Group Tax Managers
- Tax Managers
- Corporate Financial Consultants/ Advisors
- Entry to mid-level tax employees at MNE’s or Revenue Services
- Revenue Service Officials
- In house tax specialists of MNEs;
- Head of Transfer Pricing;
- Head of Tax
- Group Tax Manager
- Tax Director
- Head of Corporate Tax
- Tax Manager
- Head of Group Taxation
- Tax Partner
- Senior Tax Consultant
- Partner.
Next Intake
The next intake will take place after final validation by Middlesex University. It is anticipated to be in the second quarter of 2022.
