Eduardo Baistrocchi

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 has a limited number of places and demand is typically high. This may mean that you’re not able to get a place on this course.

There are no formal pre-requisites for this module.

The course offers a comprehensive analysis of the taxation of multinationals, focusing on transfer pricing. It offers both theoretical and practical understanding of the fundamentals of this fascinating topic. 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 a number of jurisdictions, including G20 countries and non-G20 global tax hubs.

This course will have 20 hours of teaching content in Lent Term and two additional hours of teaching in the Summer Term. There will be a Reading Week in Week 6.

Students will have the option of producing a formative essay of 2,000 words.

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

Sample readings include:

Báez, Andrés and Brauner, Yariv, Taxing the Digital Economy Post BEPS ... Seriously (March 1, 2019). University of Florida Levin College of Law Research Paper No. 19-16, Available at SSRN: https://ssrn.com/abstract=3347503 or http://dx.doi.org/10.2139/ssrn.3347503

E. Baistrocchi, Article 9: Associated Enterprises — Global Tax Treaty Commentaries, Global Tax Treaty Commentaries, International Bureau of Fiscal Documentation, 2022. Available at: https://www.ibfd.org/news/global-tax-treaty-commentaries-gttc

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.