Course Overview
This module gives you the required knowledge, skills and understanding of the fundamentals of transfer pricing, based on the OECD model, that you need to succeed in your career. You will gain detailed knowledge of functional analysis, the arm’s length principle, comparability, compliance issues, and avoiding double taxation and dispute resolution.
Target Audience:
- Professionals around the world, particularly tax advisers
- Professionals working with multinational corporations
- In-house tax practitioners at large corporate firms
- Senior-level professionals, managers or those working towards a senior level
Topics Covered
- Fundamental Sources
- The Arm’s Length Principle (ALP)
- Functional Analysis
- Transfer Pricing Methods
- Comparability
- Specific Transactions
- Permanent Establishments (PE)
- Compliance Issues
- Avoiding Double Taxation and Dispute Resolution
- Specific Transactions
- Other Issues
Main Tutor’s Profile
Prof. Mario Greggi is a full professor at the University of Ferrara, Department of law and Professor at the University of Bologna, European School of Advanced Tax Studies. Director of the Ph.D Course in EU law and National Legal Systems. Admitted to the Italian Bar. Professor Greggi is also a member of the Scientific board of the Review “Novità Fiscali” (Lugano, Switzerland) and of the Editorial board of “European tax Studies” (Bologna, Italy). In 2008 he was appointed as Honorary Research Fellow at the Department for business law and taxation of the Monash University in Melbourne (Australia). Prof. Mario was invited as a guest and speaker in numerous seminars and conferences internationally including Australia, Russia, Hong Kong, Brazil, Iran, Israel and many others.
Prof. Christiana HJI Panayi is a Professor in Tax Law at Queen Mary University of London. She teaches on the EU Tax Law, International Tax Law and Transfer Pricing courses of the LLM Programme. In the past, Christiana was also an Adjunct Professor of European Union Tax Law at New York University, a Visiting Professor at Sorbonne University (Ecole de droit de la Sorbonne, Université Paris 1), a Visiting Professor at WU Vienna and a Visiting Professor at the University of Lausanne. Professor Panayi has published extensively in the area of EU and International Tax Law and is considered a leading expert in her field. She speaks regularly at tax conferences and teaches abroad. Christiana has been appointed twice as an expert member at the European Commission’s Joint Transfer Pricing Forum (JTPF) and the Platform for Tax Good Governance. Christiana studied at the University of Oxford for her BA in Jurisprudence and for the BCL. She also has a PhD from the London School of Economics. She is a solicitor of England and Wales and an advocate of the Cyprus Supreme Court. Before joining Queen Mary, Christiana worked for Allen and Overy LLP. Christiana is also a member of the Law Society of England and Wales, and the Cyprus Bar Associatio
Mr Daniel Beeton is Of Counsel in the Tax Law practice of Arendt & Medernach where he is the senior economist in the Transfer Pricing practice. He advises clients on the determination of arm’s length prices for all types of related party transactions, including goods, services and intellectual property, but with a special focus on financial transactions such as loans, guarantees, group treasury policies and asset management fees. Danny’s assistance is sought in the context of transfer pricing compliance and reporting, controversy and planning, and he has provided expert reports in the context of litigation. Danny also brings his economics skills to bear in EU state aid matters and in giving general business advice to family-owned businesses. He has been a member of two HMRC advisory committees, and committees of the Confederation of British Industry and the Chartered Institute of Taxation. Until recently he was Editor-In-Chief of the journal Transfer Pricing Forum. He has been listed in Chambers Tax, World’s Leading Transfer Pricing Advisors and World’s Leading Tax Controversy Advisors. Daniel began his teaching career in the University of London, where he continues to gives post-graduate classes in transfer pricing. He is regular speaker at Tax conferences around the world. He holds a Master’s degree in Economics from the University of Essex as well as a PhD in Economics from the University of London.
Assessment
Assessment is done in a 3-hour exam issued by the Charter Institute of Taxation. All questions are designed to test the student’s application of concepts to real-world scenarios.
Qualification
The Advanced Diploma in International Taxation (ADIT) is the only International recognised Diploma in Taxation in Malta through the Chartered Institute of Taxation (UK), which is the leading taxation professional body in the United Kingdom and is delivered in Malta through the Malta Institute of Management (MIM).
This course is an internationally recognised qualification that is considered to be at a level of a post-graduate professional qualification. It consists of 3 modules; Principles of International Tax (1), Maltese Taxation (2) and Transfer Pricing (3).
Completion of ADIT Transfer Pricing
In completing ADIT Transfer Pricing, students will obtain a standalone certificate to recognise their achievement of a single ADIT exam. Furthermore, students who successfully complete the Transfer Pricing course have the option to continue their studies in the other ADIT modules and achieve a postgraduate professional qualification within 5 years. Holders of the ADIT qualification will receive an ADIT qualification certificate together with an invitation to an ADIT Awards Ceremony. ADIT holders may apply to become an ‘International Tax Affiliate of the Chartered Institute of Taxation’ which will entitle them to use the designatory letters “ADIT” after their name.