Eduardo Baistrocchi, Room NAB 7.33. 

This course is available on the LLM (extended part-time), LLM (full-time) and University of Pennsylvania Law School LLM Visiting Students. This course is available with permission as an outside option to students on other programmes where regulations permit.

This course will be relevant to the following LLM specialisms: International Business Law, Taxation.

This course is capped at 30 students. Students must apply through Graduate Course Choice on LSEforYou.

Students should have at least a basic knowledge of a tax system of a country (not necessarily the UK) or be studying LL4Z1 Business Taxation.

This course offers both theoretical and practical understanding of the fundamentals of the transfer pricing problem. The course will begin with an overview of the transfer pricing issue, including its history, current importance and global trends. General concepts, special rules and the different types of transfer pricing transactions will be discussed, as well as the specific rules and methods for tangible goods, intangibles, services and loans. Finally, the course will provide a review of transfer pricing controversy in G20 countries.

20 hours of seminars in the LT. 2 hours of seminars in the ST.

This is based on a format of lecture-discussions with the possibility of guest speakers where appropriate and depending on numbers, corresponding fortnightly one-hour classes.

There will be a reading week in week 6.

Students are asked to submit one 2,000 word essay.

Detailed reading lists will be provided during the course via Moodle.

Recommended preliminary reading

E. Baistrocchi, ‘Transfer Pricing Dispute Resolution: The Global Evolutionary Path’ in E. Baistrocchi and I. Roxan (eds.), Resolving Transfer Pricing Disputes: A Global Analysis (Cambridge University Press). Available at SSRN: https://ssrn.com/abstract=2337717

Exam (100%, duration: 2 hours, reading time: 15 minutes) in the summer exam period.