Transfer pricing more than ever before is a major issue for

Assignment Help Business Law and Ethics
Reference no: EM13343519


Transfer pricing more than ever before is a major issue for companies all over the world. The need to effectively plan the movement of profits between arms of a multinational corporation has become even more critical as companies face an increasing attention from tax authorities on transfer pricing matters. As both developing and developed nations introduce more sophisticated transfer pricing rules, particularly concerning documentation, taxpayers must be fully aware of the intricacies of each set of laws. 


(i) Discuss, using appropriate examples, the concept of ‘transfer pricing’ and explain why tax authorities around the world have become concerned about it.

(ii) Discuss recent developments in the ‘transfer pricing’ environment as a consequence of how tax authorities have responded to the transfer pricing issue. Refer to the developments and changes applicable in Australia and as to how the OECD has approached this issue. 


This Research Assignment represents 20% (or 20 marks) of the total assessment. 

- 15% (15 marks) relates to your submission (due Mon 6th October 2014) 

- 5% (5 marks) relates to your class presentation (week beg 6th Oct 2014) 

Due Date: Written submission due on Monday 6th October 2014 (5pm) 

- Group Presentations in Class week beginning 6th October 2014 

Word Length: 2,000 words (excluding footnotes, references and appendices). 


- The assignment can be submitted individually or as a group. A group may consist of up to 4 students. 

- This is a research assignment and as such your report should provide your personal/group view based on research evidence, theory and original thought. 

- A class presentation of your report is due in week beginning 6th Oct 2014 

- The assignment must have correctly referenced appendixes. 

- You can refer to the information contained in your additional readings below. 

- You will need to access the CCH library information link which is on blackboard. 

- A good starting point for this assignment would be Chapter 49 of your text book and the website of the ATO (available at: 

- Other references which will be of assistance are as follows: 



Barkoczy, S.; Foundations of Taxation Law; CCH Australia, Chapter 49 

Woellner et al; Australian Taxation Law; CCH Australia, Chapter 24 

Australian Master Tax Guide; CCH Australia, Chapter 22 


Treasury discussion paper Nov 2011 

Treasury submissions, exposure draft & draft explanatory memorandum 

Tax Laws Amendment (Cross-Border Transfer Pricing) Bill (No. 1) 2012 

Explanatory memorandum 

Browse the Articles of the OECD Model Tax Convention on Income and Capital at 

Priority of Australia’s International Tax Agreements 

OECD Model Tax Convention articles on associated profits (article 9) and the mutual agreements procedure (article 25). 

Arm's length methods 

1. TR 98/11 four step process to implementing 

2. TR 97/20 five methodologies 

3. PS LA 2011/1 advance pricing agreements 


Presentation is an important feature of any Research report. The following guide to presentation gives a general outline to report writing. 

Title Page 

Table of Contents 

Executive Summary (should not exceed 300 words) 

Introduction and Purpose 

- State aims of the research report 

- Outline contents of research report 

- Sources of data Body of the Report 

- Analysis and discussion of issues 

- Interpretation and discussion of data Conclusion 

- Summary of your analysis and interpretation; findings and results of your work Appendices 

- Include raw data, charts and tables that are not essential to be included in the body of your report 

- Calculations used or referred to Bibliography 

- References used 


- Groups must present the main findings from their research including a critical analysis of the issues involved. Group to decide which member(s) of group present. 

- Presentation is limited to 15 minutes per group. 

- Presentation will be via use of ppt slides. 


The assignment can be submitted individually or as a group. A group may consist of up to 4 students. A group project is the collective responsibility of the entire group, and if one member is temporarily unable to contribute, the group should be able to reallocate responsibilities to keep to schedule. In the event of longer-term illness, other serious problems involving a member of a project group or where equal contributions are not forthcoming and this cannot be resolved by the students themselves, it is the responsibility of the other members to make the project supervisor aware of the situation straight away. 

The assignment must be submitted with a duly filled assignment cover sheet. All group members must be satisfied that the work has been correctly submitted. Any penalties for late submission will apply to all group members, not just the person who submitted. The penalty shall be at the rate of 2 marks per day late (including due day of report – if after 5pm). 


To avoid plagiarism, you are required to provide a reference whenever you include information from other sources in your work. Further details regarding plagiarism are available in Section C of the unit outline. 

Referencing convention required for this unit is the Swinburne Harvard System. Helpful information on referencing using the Swinburne Harvard System can be found at:

Reference no: EM13343519


Write a Review


Business Law and Ethics Questions & Answers

  International and comparative law

International and Comparative Law

  Discuss the market segmentation within that industry

Write a white paper on a company of your choice and discuss the market segmentation within that industry along with the target market for the company and the selection process for that target market.

  Explain should managers consider race in the hiring equation

Explain Should Managers Consider Race in the Hiring Equation and The issue of diversity is a major topic for government suppliers that have to supply census data about their workforce relative to the race of candidates that they hire for opportunit..

  Objectives and purpose of workers compensation legislation

Discuss agency from the point of view of actual, implied, and apparent authority, estoppel, fiduciary duty, breach of duty, ratification, and vicarious liability and explain how the court will determine whether a person is an ..

  Infringement for phoneson and singatron

What are some IP areas that can be at risk for infringement for Phoneson and Singatron if not properly mitigated - Semicontronics should include in their contract to have Singatron manufacture computer chips.

  Explain sources of business law

Explain Sources of Business Law and What is the difference between common law and statutory law

  Yolande and shani control the business

Yolande and Shani control the business, and Wei, who is Yolande's boyfriend, has little interest in the company and little knowledge about its affairs.

  Is the analysis employed by the court in a case

Is the analysis employed by the court in a case involving commercial speech B) is the analysis employed by the court in deciding an equal protection case involving discrimination on the basis of race

  Ethical and legal principles to issues that pertain to sell

Apply relevant ethical and legal principles to issues that pertain to selling.

  John, lionel, and evelyn harrymore, siblings and actors

John, Lionel, and Evelyn Harrymore, siblings and actors, decide to retire after years on the road. They remember a town in Illinois they were familiar with from their travels. From the internet, they learn of a farm a few miles outside of town that s..

  What potential ethics issues do you see in situation

What potential ethics issues do you see in situation and which AICPA Code(s) of Professional Conduct rules apply in this situation (explain how and why they apply)?

  Explain employment law- justifying employer actions

Explain Employment Law- Justifying Employer Actions and The assistant manager was alerted by a co-worker that the female employee in question had just walked from the front of the store

Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd